NCCS submitted comments to the Centers for Medicare and Medicaid Services (CMS) in response to its request for feedback on the implementation key provisions of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Specifically, we offered comments on alternative payment models for cancer care as part of the Merit-Based Incentive Payment System (MIPS).
NCCS believes there is great promise in the patient-centered oncology medical home (PCOMH) as an alternative payment model for cancer care, and we recommended that a variation on the PCOMH be designed to provide care to survivors of cancer as they move from active treatment to survivorship. The numbers of cancer survivors among Medicare beneficiaries and their complex chronic care needs argue for efforts to design a cancer survivorship model and to find flexible approaches for such a model in a physician-focused reform system. We offered additional comments related to cancer treatment planning and coordination and measures of resource use.
Additionally, NCCS signed a letter from the Cancer Leadership Council that proposed an alternative payment system for cancer survivorship care and commented on two of the performance measures under MIPS.