Posts

NCCS Policy Comments HHS bldg

NCCS Submits Recommendations to CMS Regarding Proposed Changes to Hospital Outpatient Prospective Payment System (OPPS)

/in , , , , , , , , /by
Department of Health and Human Services (HHS)

NCCS submitted a letter to the Centers for Medicare and Medicaid Services (CMS) on the proposed update to the hospital outpatient prospective payment system, known as OPPS, for calendar year 2019.

In the letter, NCCS addresses the proposed change in payment for clinical services that are provided at off-campus provider-based departments. While the proposal will reduce cost-sharing for patients for clinic visits, NCCS recommends evaluation of the potential unintended consequences of the change. Additionally, CMS included a “request for information” in the proposed rule on the topic of price transparency. NCCS endorses the idea of price transparency, but also has concerns about how patients utilize this information given their individual cost-sharing associated with that care.

NCCS writes:

Perhaps in some circumstances they will be motivated to alter their decisions based on the overall cost of care and concerns about the impact of those costs on the health care system, but that is not the primary source of action for cancer patients.

Finally, NCCS commented in favor of reforming the drug acquisition program, called the Competitive Acquisition Program (CAP), which is a voluntary program that offers physicians an option to acquire Medicare Part B drugs from vendors who are elected in a competitive bidding process. NCCS suggests the CAP should be accompanied by improvements to the way cancer care professionals are paid for the services they provide. NCCS outlines several considerations for CMS to avoid mistakes made in the previous CAP implementation.

Read the full NCCS letter below.

Download the Comment Letter [PDF] (Right-click, save as)

NCCS Logo

 

September 24, 2018

Seema Verma, MPH
Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201

Re: CMS-1695-P, Medicare Program: Proposed Changes to Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs; Requests for Information on Several Issues

Dear Administrator Verma:

The National Coalition for Cancer Survivorship (NCCS) is a national organization engaged in public policy efforts to ensure access to quality care for survivors of all forms of cancer. We have pursued reforms of Medicare payment for cancer care as a means to enhance the overall quality of the system. We appreciate the opportunity to comment on the proposed update to the hospital outpatient prospective payment system for calendar year 2019.

Encouraging Site Neutrality in Payment for Clinic Visits

In the last decade, changes in ownership of oncology practices have resulted in more cancer care services being provided in off-campus provider-based departments (PBD) that are paid under the outpatient prospective payment system (OPPS). This has resulted in increased cost-sharing for cancer patients, due to the higher rates of payment under OPPS, compared to payments under the physician fee schedule. This is a serious concern for cancer patients, many of whom face financial toxicity because of their cancer treatment.

Some cancer experts contend that the consolidation of oncology practices and the increased ownership by hospital systems has resulted in improvements in the availability and quality of supportive care services for patients in those off-campus provider-based departments. Others suggest that there are not significant differences in the care delivered in oncology practices that are independent and care in those practices those operating as off-campus sites of hospitals.

The proposal to apply a physician fee schedule (PFS)-equivalent rate of payment for clinical services that are provided at an off-campus provider-based department (PBD) that is paid under the outpatient prospective payment system will provide relief to cancer patients through the reduction of their cost-sharing for clinic visits. The agency projects that the application of PFS-equivalent rate for PBD services will reduce the payment for clinic services from approximately $116 to approximately $46, with a corresponding reduction in the average beneficiary cost-sharing from $23 TO $9.

Although the reduction in beneficiary cost-sharing responsibility is a positive, we recommend that changes in the payment for clinic services provided in PBDs be undertaken only after evaluation of the possible unintended consequences of this reimbursement change. Just as there were unintended consequences from the consolidation of oncology practice ownership through hospital acquisition, so there may be consequences from payment for PBD services at the PFS rate.

Request for Information on Price Transparency: Improving Beneficiary Access to Provider and Supplier Charge Information

CMS has included in the proposed rule a “request for information” on the topic of price transparency. NCCS endorses the fundamental concept of health care cost transparency. However, we have basic questions about what information about health care costs is important to and actionable by patients as well as questions about how to achieve transparency in the system.

Even if comprehensive information about all elements of care could be provided to cancer patients, we are not persuaded that such information would be useful to them unless it was accompanied by accurate and timely information about their insurance policies and how those policies will cover and pay for the care they need. They need clarity that their insurance will cover they care that they need and that they can manage the cost-sharing associated with that care. Patients are more likely to act based on how health care costs will affect them, which means what their cost-sharing responsibilities will be. Perhaps in some circumstances they will be motivated to alter their decisions based on the overall cost of care and concerns about the impact of those costs on the health care system, but that is not the primary source of action for cancer patients.

In recent months, much attention has been directed to “surprise” emergency department charges and also surprise out-of-network provider charges. Some have suggested that these matters can be addressed at least in part by transparency about emergency department charges and also out-of-network charges. Although we support transparency regarding these charges, we do not believe that transparency will fully address the financial exposure of consumers. Instead, consumers must have protection related to third-party coverage of emergency department charges and solid information about how their payers will cover out-of-network services.

The experience related to communication of cost of care in the Oncology Care Model also underscores the difficulties in achieving transparency in cost of care. The initial objection in the Oncology Care Model was for participating practices to communicate the total cost of care to patients. Upon receiving feedback from OCM participating practices regarding the difficulty of obtaining and communicating the data related to total cost of care, the requirement was modified to relate to patient cost of care. The feedback from OCM practices is that the responsibility for communicating patient cost of care is a significant burden. Expanding that responsibility to require communication regarding overall cost of care is not advisable.

If a goal of transparency is to inform policymakers and patient advocates and to motivate their action related to health care pricing, the agency must give considerable thought to how to provide comprehensive and accurate pricing data as well as how to publish and publicize those data to a broad audience. Efforts related to pricing information to date have not achieved the goals of accuracy and comprehensiveness. Even if CMS can set standards and encourage compliance with requirements for pricing disclosure, the impact of that effort is still not clear. If the collection and dissemination of pricing information is to have an impact beyond generally improving public awareness of health care costs, the agency must determine if it wishes to encourage use of the data by public and private payers and consumers and how it can encourage that use.

While these serious questions are evaluated and addressed, we encourage immediate action to inform patients about their out-of-pocket responsibilities, which may require the imposition of information-sharing responsibilities on third-party payers.

Request for Information on Leveraging the Authority for the Competitive Acquisition Program (CAP) for Part B Drugs and Biologicals for a Potential CMS Innovation Center Model

For some time, NCCS has advocated an end to the buy-and-bill system for acquisition of physician-administered drugs under Medicare Part B. We favor a reform of the drug acquisition system, to be accompanied by improvements in the payment for services provided by cancer care professionals. We understand the concerns that the buy-and-bill system, which incorporates a reimbursement formula of ASP+6 percent, may incentivize the use of more expensive drugs. We believe that the evidence on that issue is mixed and that is not the primary motivation for our support of reform. However, by reforming the Part B drug acquisition system, that issue will be addressed. In addition, the concerns among some oncology practices regarding the costs of acquiring and storing drugs will be addressed by buy-and-bill reforms. Changing the drug reimbursement system also creates the opportunity to improve overall the manner in which cancer care professionals are reimbursed for their services.

The agency seeks comment on how to implement the competitive acquisition system and to avoid the mistakes of the previous CAP implementation effort. We identify the following issues for consideration by CMS in testing CAP again:

  • CAP should not block or slow patient access to drugs. In the previous test of CAP, the vendor would delay shipment of drug if there were questions about payment of patient cost-sharing. Sophisticated billing software is available, and we expect that vendors can utilize such software to manage patient billing and to protect against delays in drug shipments that harm patients.
  • CAP should not be utilized to implement a restrictive formulary in the Medicare Part B program. We have expressed our opposition to the plan to permit Medicare Advantage plans to use step therapy strategies beginning in 2019, and we would also oppose utilizing CAP as a means to limit patient access to cancer therapies in Part B.
  • The request for information lists a number of different pricing and reimbursement systems that might be tested through CAP. We are concerned that the agency is attempting to test too many concepts through CAP. There are important problems that arose in the initial CAP program that must be addressed, including ensuring timely shipments, addressing issues related to beneficiary cost-sharing, and guaranteeing robust provider participation to support a solid evaluation of the program. We think that the request for information may be overly ambitious in identifying a wide range of pricing and reimbursement systems for testing while fundamental questions about the workability of the distribution system are addressed. Also, as noted above, we do not support the implementation of CAP as a means of imposing a restrictive formulary in Part B. As we argued in connection with the step therapy proposal, such a plan is at odds with the needs of cancer patients in an age when therapies are increasingly personalized.

The Part B drug payment system is generally recognized as a system that subsidizes the cost of physician services in providing cancer care. If the CAP system serves as a major overhaul of the drug distribution system, it should be accompanied by reforms in payment for physician services. We understand that the OCM is a major test of episodes in cancer care that is still underway. However, if CMS intends to move forward with CAP, it is necessary to address those services still reimbursed outside the OCM on a fee-for-service basis.

We appreciate the opportunity to comment on proposed reimbursement changes for 2019 and RFIs that suggest additional, major changes in Medicare reimbursement in the near future. We look forward to ongoing discussion with CMS on the topics of the RFIs.

Sincerely,

Shelley Fuld Nasso, MPP
Chief Executive Officer

# # #

Download the full letter to the Centers for Medicare and Medicaid Services (CMS) » [PDF]

Read more NCCS Policy Comments »

NCCS Policy Comments HHS bldg

NCCS Raises Concerns Over Impact on Patients of Medicare Physician Fee Schedule Revisions

/in , , , , , , , , , /by
Department of Health and Human Services (HHS)
NCCS submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the Medicare physician fee schedule revisions proposed for calendar year 2019 and proposed revisions in the Quality Payment Program.

In our comments, NCCS addressed proposed changes to evaluation and management services, which are provided in the office or outpatient setting and are a critical element of cancer care. CMS proposed creating a composite code for evaluation and management services, rather than the existing codes that recognize levels of complexity and intensity of the service provided. We raised concerns about the significant impact the changes will have on cancer care providers, and in turn, on cancer patients, who have complex needs and require sufficient time with their medical team.

NCCS does not support the changes in E/M codes and payment. The recommended change is a departure from the resource-based relativity of the fee schedule. If such a change is to be made, it should be undertaken only with significantly more discussion about the implications of such a shift in payment and consideration of other payment options. The proposed rule does not include any serious discussion of the magnitude of this change and its implications for patients.

NCCS also commented on the Quality Payment Program, which we believe has significant value. NCCS supports the efforts to strengthen the program, to ensure that more clinicians participate in the program, and to provide a valid basis for evaluating clinicians and comparing performance.

In addition to submitting our own comments, NCCS signed comment letters with the Cancer Leadership Council and the Consumer-Purchaser Alliance.

Read the full NCCS letter below.

View/download the Cancer Leadership Council (CLC) letter »
View/download the Consumer-Purchaser Alliance letter »

NCCS Logo

 

September 10, 2018

Seema Verma, MPH
Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201

Re: CMS-1693-P, Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2019

Dear Ms. Verma:

The National Coalition for Cancer Survivorship (NCCS) is a national organization engaged in public policy efforts to ensure access to quality cancer care for survivors of all forms of cancer. We appreciate the opportunity to comment on the Medicare physician fee schedule revisions proposed for calendar year 2019 and proposed revisions in the Quality Payment Program. We focus our comments on the impact of these proposals on cancer patients and their access to quality care.

Changes in Evaluation and Management Payments

Evaluation and management (E/M) services, provided in the office or outpatient setting, are a critical element of cancer care. Cancer care is planned, complex treatment is provided, symptoms are managed, and patients receive “care” in E/M visits. Because of the importance of E/M services for Medicare beneficiaries and also the significant Medicare expenditures for these services, it is understandable that the Centers for Medicare & Medicaid Services (CMS) would direct its attention to these services and how they are reimbursed. However, we think that the proposed changes in E/M payment should be reconsidered.

CMS has proposed to combine the level 2-5 codes into one composite code and to require that Medicare providers only document a level 2 visit to receive the new composite code. CMS also added two additional options (time and medical decision-making) for providers to document the level of E/M services that they bill. The agency stresses the importance of the changes in documentation, which it says will reduce the burden of documentation on providers and improve the quality of the interaction between providers and patients in the E/M visit. In the proposed rule, the changes in documentation and the E/M composite code are linked, and there is the implication that the reduction in the documentation burden justify the payment changes.

NCCS does not support the changes in E/M codes and payment. The recommended change is a departure from the resource-based relativity of the fee schedule. If such a change is to be made, it should be undertaken only with significantly more discussion about the implications of such a shift in payment and consideration of other payment options. The proposed rule does not include any serious discussion of the magnitude of this change and its implications for patients.

Many E/M visits for cancer patients are level 4 and 5 because of the time and medical decision-making required for the visit. As a result, the plan to pay a composite rate for level 2 to 5 visits will have a significant impact on cancer care providers. The impact may be especially significant for those oncology practices with a mix including more complex patients. We are concerned that there will be a significant negative impact on cancer patients as a result of the E/M payment changes.

If the proposed changes in documentation in fact have a positive impact on the interaction between patients and providers in E/M visits, as the agency suggests, the changes should still not be accomplished at the expense of E/M payments.

We note that CMS, in addition to proposing a composite rate of payment for level 2 to 5 visits, proposes add-on codes for primary care, add-on codes for certain specialty care, and a new prolonged E/M code (for an additional 30 minutes of clinician time). Those professionals who are providing cancer care are likely to be providing E/M services that will qualify for the add-on specialty care code and the prolonged E/M code. CMS has identified hematology/oncology as one of the specialties for which the add-on code and prolonged visit code might be utilized. We urge CMS to clarify that not only these specialists but also others who are providing cancer care – radiation oncologists, surgical oncologists, and others – should also be permitted to use the add-on and prolonged visit code. Finally, we recommend that CMS clarify the frequency with which the codes may be used and offer assurances that use of these codes will not trigger audits of providers.

Although we support the add-on codes and prolonged visit codes, we believe that they should have been proposed even without the recommendation of a composite code for level 2 to 5 visits. If CMS reconsiders the composite code, as we recommend, it should not abandon the add-on codes and prolonged visit code. For a number of years, NCCS and its colleagues in the cancer community have advocated a code for cancer care planning and coordination. We believe that certain cancer care E/M visits require complex medical decision-making related to treatment planning and care coordination and also require significant time. For these E/M visits, we have suggested a special code and payment acknowledging the nature of the service. The add-on code and prolonged visit code are consistent with the rationale we offered to describe the cancer care planning code. We urge that they be retained by CMS, at least for use by cancer care providers, even if the composite code is reconsidered.

A Working Group to Review E/M Codes

The American Medical Association and other medical societies have recommended that the E/M code changes be withheld while a working group of medical professionals offers advice to CMS about a more comprehensive overhaul of E/M codes. We support this recommendation, and NCCS will seek to participate in any discussion about E/M codes that is undertaken, in order to provide a patient perspective on quality E/M services. Patients who receive important care through E/M visits have experience that permits them to provide advice about structuring such visits for optimal provider-patient interaction.

Quality Payment Program

We believe that there remains significant value in the Quality Payment Program, and we support the efforts to strengthen the program, to ensure that more clinicians participate in the program, and to provide a valid basis for evaluating clinicians and comparing performance. To that end, we support the requirement that providers continue to report quality measures for a full-year rather than just 90 days. However, we have misgivings about the proposal to extend the delay in public reporting of quality measures from one year to the first two years that a measure is used in the quality performance category. We are also concerned about the low-volume thresholds, because they result in exempting many clinicians from required participation in the program. Finally, we caution against the continuation of the menu approach to measure selection in the quality performance category. These actions combine to slow the progress in full implementation of the QPP and in fostering evaluation of more clinicians reporting a consistent set of measures.

We commend CMS for proposing to adopt four patient-reported outcome measures. These include three measures related to average change in functional status following lumbar spine fusion surgery, following total knee replacement surgery, and following lumbar discectomy laminotomy, as well as average change in leg pain following lumbar spine fusion surgery. Patient-reported outcome measures like these provide information about care and functional status that cannot be obtained from other sources. We are especially pleased to see the emphasis on change in functional status. Consistent with our view that this is an important measure for understanding patient quality of life, we are undertaking a patient-driven measure development process toward a measure of return to functional status after cancer treatment.

In response to the CMS request for input about the patient-reported outcomes (PROs) that improve clinical outcomes, we offer our view that PROs are important for the information that they convey about patient response to treatment and care. For example, PROs that provide information about quality of life and improved functioning are important even if they do not provide information about improvement in clinical outcomes. As stated above, that commitment to patient-reported outcome measures (PROMs) has prompted NCCS to be engaged in a patient-focused measure development effort related to return to functional status after cancer treatment.

* * * * * * * * * *

NCCS appreciates the opportunity to comment on proposed changes in the physician fee schedule and Quality Payment Program for 2019. We look forward to additional discussion with CMS regarding strategies to make E/M visits truly patient-centered.

Sincerely,

Shelley Fuld Nasso, MPP
Chief Executive Officer

# # #

Download the full letter to the Centers for Medicare and Medicaid Services (CMS) » [PDF]

Read more NCCS Policy Comments »

Related Posts

NCCS Joins Cancer Leadership Council Comment Letter Regarding the Drug Pricing Blueprint “American Patients First”

NCCS Statement on HHS Final Rule for Short-Term, Limited Duration Health Plans

NCCS Policy Comments HHS bldg

NCCS Statement on HHS Final Rule for Short-Term, Limited Duration Health Plans

/in , , , , , , , , /by
Department of Health and Human Services (HHS)

The National Coalition for Cancer Survivorship (NCCS) issued the following statement regarding the Trump administration’s announcement of the final rule on short-term, limited-duration health insurance plans:

“NCCS is deeply concerned that the administration’s new rule on short-term, limited-duration plans, called ‘junk insurance’ by health insurance experts, will harm cancer patients and survivors by providing inadequate coverage for cancer care and by driving up premiums for comprehensive plans that cover the health care needs of those with cancer. While the administration touts the affordability of these plans, affordability comes at the expense of coverage. Encouraging the use of short-term plans breaks the promise of the administration and Members of Congress to protect people with pre-existing conditions.

“Millions of cancer survivors were relieved when Congress rejected efforts to repeal the Affordable Care Act (ACA) last year, but now the administration is again eroding the ACA protections. Short-term plans do not have to cover people with pre-existing conditions and are not required to offer benefits such as maternity care, prescription drugs, or preventative care. These plans will not help people with a history of cancer or people who will be diagnosed with cancer. Additionally, these barebones plans will attract young and healthy individuals, leaving older and sicker individuals in the individual market. Premiums in the individual market will go up and choices may go down. People with cancer and cancer survivors who rely on the individual market for insurance will find that adequate and affordable insurance is beyond their reach.

“NCCS is concerned that individuals will buy short-term plans thinking they are getting a good deal until the moment they need health care services, or worse, face a diagnosis of cancer, when they will be stuck with enormous out-of-pocket costs. These plans are NOT a substitute for the comprehensive health coverage that the ACA ensures. By expanding and promoting short-term limited-duration plans, the administration is taking patients back to the days when insurance companies denied individuals who are sick and excluded coverage for the care that cancer survivors need.”

# # #

Related Posts

https://www.canceradvocacy.org/policy-comments/nccs-letter-association-health-plans-increase-costs-cancer-survivors/
https://www.canceradvocacy.org/policy-comments/statement-president-trumps-harmful-health-care-executive-order/

Read more NCCS Policy Comments »

NCCS Starburst 250px

Health Care Roundup: “Toxic Town” in WV Battles High Cancer Rates; CMS News: Risk Adjustment, 340b, Site-Neutral Payments; Hospital Costs; More

/in , , , , /by

In order to bring you the latest cancer-related health care policy and news, we at NCCS combined our ACA Updates and What Caught Our Eye (WCOE) content into a weekly email and blog post. We aim to make this a concise, one-stop summary of what you need to know as we continue working together to make cancer care better for everyone.

Your feedback is always welcome to make our content more useful to you. Please send comments to feedback@canceradvocacy.org.

Subscribe to our email list and receive these updates in your email box each week »

HEALTH CARE HIGHLIGHTS

CMS Resumes ACA Risk Adjustment Payments

The Centers for Medicare and Medicaid Services (CMS) announced it will continue payments—amounting to $10.4 billion—to the Affordable Care Act’s (ACA) risk-adjustment program. The program was established to ensure that risk is spread across insurance companies.

Recently, in one of the many efforts to dismantle the ACA, CMS announced that it would halt the payments, highlighting concerns about the risk-adjustment formula from a federal judge’s ruling in New Mexico.

Insurers responded to CMS’ move by warning about the possibility of raising next year’s ACA premiums due to unpredictability of risk adjustment payments. In a statement regarding the decision to allow payments to be made to insurers again, CMS Administrator Seema Verma said:

Issuers that had expressed concerns about having to withdraw from markets or becoming insolvent should be assured by our actions today. Alleviating concerns in the market helps to protect consumer choices.

– CMS Administrator Seema Verma

Additional Cuts Proposed to 340B Drug Program

CMS is seeking to make further cuts to 340B drugs at hospital off-campus sites in a proposed rule released on Wednesday. The 340B program allows hospitals to buy certain drugs at a lower cost. CMS is now proposing to make additional cuts to 340B hospitals by extending these cuts to an even greater number of off-campus hospitals and outpatient clinics. This proposal could harm patients’ access to care, especially for vulnerable populations who rely on 340B hospitals for their care.

In 2018, CMS implemented a payment policy to help beneficiaries save on coinsurance on drugs that were administered at hospital outpatient departments and that were acquired through the 340B program—a program that allows hospitals to buy certain outpatient drugs at a lower cost.

Due to CMS’s policy change, Medicare beneficiaries are now benefiting from the discounts that 340B hospitals enjoy when they receive 340B-acquired drugs. In 2018 alone, beneficiaries are saving an estimated $320 million on out-of-pocket payments for these drugs. For 2019, CMS is expanding this policy by proposing to extend the 340B payment change to non-excepted off-campus departments of hospitals that are paid under the Physician Fee Schedule.

Hospitals that take part in the 340B program will undoubtedly push back aggressively on this proposed rule. The Association of American Medical Colleges responded, “CMS' proposal to cut Medicare payments to existing outpatient departments for clinic services runs counter to Congressional intent and would seriously damage the ability of the nation's teaching hospitals to serve the most complex and vulnerable patients.”

CMS Seeks Site-Neutral Payment Policies

In another move that is adding further frustration for hospital groups, CMS announced they intend to adopt site-neutral payment policies.

As an Inside Health Policy article explains it:

The proposed rule would establish a payment rate for hospital outpatient clinic visits equivalent to what those services would be paid under Medicare's physician fee schedule–which would amount to 40 percent of what CMS currently pays under the Outpatient Prospective Payment System.

The article went on to say:

CMS Administrator Seema Verma said on a call with reporters that she wants to end Medicare policies that pay different rates for similar services based on the type of site where the services are provided.

“This would put all providers on a level playing field, so CMS is not tipping the scales toward one site of care,” Verma said.

If finalized, the change would result in a significant reduction in payments to hospitals. We will continue to monitor these changes as they may impact patients’ access to care.

CHART OF THE WEEK

Think drug costs are bad? Try hospital prices

Bob Herman, Axios.com

Per capita health expenditures, 2000 – 2016.
Data: Centers for Medicare & Medicaid Services
Chart by Kerrie Vila, Axios

IMPORTANT READS

Gender Equity in Health Care Still Has a Way to Go

Via HealthCareDive.com

This brief highlights the concerns many female health care professionals still face when it comes to gender parity. While many are happy to see the shift towards a more gender equitable workplace still ongoing, more and more women continue to speak out on issues relating to sexual harassment and the wage gap, as well as, racial discrimination for women of color.

Read More »

A toxic town, a search for answers

Via Washington Post

Cancer clusters remain a frightening environmental and public health concern for all Americans. Physician Ayne Amjad is one of the many who have been deeply affected by her town’s history of mismanaging toxic waste that led to the “illnesses plaguing [the] town.”

This report delves into the history of industrial chemical dumping in Milden, West Virginia, the community’s overwhelming cancer rates and deaths, and Amjad’s search to connect the two. Following the footsteps of her physician father, who passed away from cancer himself, Amjad remains dedicated to carry on his work in not only learning more about the link, but to bring justice to the people who will continue to struggle under the burden of cancer for years to come.

Read More »

Want healthier communities? Address social factors

Via Public Health Newswire

The “social determinants of health” continue to pave the way for how we look at and address community and population health, shared Ceci Connolly, CEO of Alliance of Community Health Plans, as she discussed the importance of improving the incorporation of social determinants into community health plans.

Connolly outlines how these health plans can better serve beneficiaries, providing examples such as “treat the whole person”, “meet people where they are”, “speak their language”, and “address economic and housing insecurity.” These social determinants must get more attention, as the article points out that “public health professionals are well aware that 75 percent of the factors affecting our health are believed to be non-medical, such as homelessness, hunger and lack of transportation.”

Read More »

Hospital’s experiment in sedating patients without consent raises ethical concerns

Via Washington Post

Hennepin Healthcare System in Minnesota faces mounting scrutiny and anger for their practice of sedating patients without consent, then using results for research. Patients with agitation who were taken by ambulance were given powerful drugs without their consent and were later informed by Hennepin that they were subjects in a study that compared the effectiveness of different sedatives-most notably ketamine- on patient agitation. Hennepin responded to inquiries about their practices, emphasizing the hospital system’s dedication to transparency and “integrity of scientific research.”

Read More »

Related Posts

Health Care Roundup: Trump Drug Pricing Plan; HHS Cuts ACA Navigator Funding; CAR-T Therapy Coverage Issues; Biosimilar News; and More

NCCS Joins Cancer Leadership Council Comment Letter Regarding the Drug Pricing Blueprint “American Patients First”

ProtectOurCare 1024px

ACA Update February 16, 2018 | Idaho Insurer Rolls Out Health Plans That Violate ACA Regulations, Including Pre-Existing Condition Protections

/in , , , /by

AHCA

Prior to the Affordable Care Act (ACA), cancer survivors were at the mercy of the health care system, often forced to pay exorbitant premiums or simply denied coverage altogether. Today, America’s 16 million cancer survivors benefit from the ACA’s patient protections that are critical to providing them with quality, affordable, and accessible health care coverage. NCCS is actively engaged in advocating to ensure this unprecedented access for cancer patients and providers continues.
Two weeks ago, NCCS reported in our ACA Update that Idaho regulators said they would allow the sale of insurance plans that don’t adhere to the Affordable Care Act’s (ACA) requirements.

This week, the state took it a step further when Blue Cross of Idaho unveiled health plans that break the ACA’s federal health laws in several ways. Blue Cross of Idaho will attempt to sell insurance plans that are priced based on applicants’ health status.

For cancer survivors, this is deeply concerning as those with pre-existing conditions will be charged outrageous amounts for their health coverage. The ACA made it illegal to discriminate based on health status, so now it will be up to the Trump Administration, and newly appointed Health and Human Services Secretary Alex Azar, to either enforce federal law or allow state regulators to move forward with these harmful policies. Allowing Idaho to sell such plans would prompt other states to take similar action to undermine the ACA, taking us back to the days when patients were subjected to expensive and/or insufficient health care coverage.

As NPR reports, at a congressional hearing Wednesday, even as Blue Cross rolled out its plans, Azar was questioned about whether the Administration will uphold the ACA’s laws. “There are rules,” Azar said. “There is a rule of law that we need to enforce.” However, he didn’t specifically indicate whether the federal government would step in. Policy analysts say that allowing lower-cost plans that don’t meet the ACA’s standards would become more widespread and pull younger and healthier people out of Obamacare, raising prices for those who remain.

NCCS will continue to monitor this development and its impact on cancer survivors.

Related Posts

ACA Update February 2, 2018 | GOP Unlikely to Try ACA Repeal Again as Trump Admin Focuses Efforts on Weakening ACA Regulations

What Caught Our Eye: Medicaid Coverage Limits; Cancer Care Cost Communication; Stanford Care Planning Study; Drug Pricing; and More

Fotolia 23428619 S e1461260836640

NCCS Submits Comments to CMS, Stresses Importance of ACA and Outlines Steps to Strengthen Law

/in , , , , , , , , , , /by
The National Coalition for Cancer Survivorship (NCCS) submitted comments to the Centers for Medicare and Medicaid Services (CMS) in response to a request for information, in which CMS asked for suggestions to empower patients and promote consumer choice, stabilize insurance markets, and enhance affordability.

In our letter, NCCS stressed the importance of the Affordable Care Act, with its pre-existing condition protections, community rating requirements, essential health benefits, and cost-sharing reductions, as a step toward providing cancer patients access to quality care without extreme financial toxicity. For many cancer survivors who did not have access to employment-based insurance prior to the enactment of the ACA and who were not eligible for Medicare, their lives have been changed by their ability to obtain insurance and access to care.

NCCS noted that the ACA needs some modifications and refinements, especially to ensure that there are plans offered in every county in the nation. To strengthen the marketplaces and foster more plan choices for consumers, we recommended several actions.

  • Cost-sharing reductions should be funded, and questions about the future of these payments should be put to rest.
  • The mandate for purchase of insurance should be enforced.
  • Funds for market stabilization should be made available in the form of payments to plan issuers with a sicker and more expensive than average pool of insured individuals.
  • Patient protections should be enhanced, including cost-sharing protections for prescription drugs and oversight of out-of-network care.

Read the full text of the letter below.

July 12, 2017

The Honorable Seema Verma
Administrator
Centers for Medicare & Medicaid Services
200 Independence Avenue, SW
Washington, DC 20201

Re:     Reducing Regulatory Burdens Imposed by the Patient Protection and Affordable Care Act & Improving Healthcare Choices to Empower Patients (CMS-9928-NC)

Dear Dr. Verma:

The National Coalition for Cancer Survivorship is dedicated to public policy efforts aimed at ensuring all cancer patients access to quality cancer care from diagnosis through treatment and survivorship. We represent the 16 million Americans who are cancer survivors. These Americans have a pre-existing condition from the moment they learn they have cancer, and many have substantial health care needs for the rest of their lives. Others may have years with minimal health care needs and costs, only to experience a recurrence that once again means they need significant cancer care services.

We are pleased to offer our advice about the design and maintenance of a patient-centered insurance market, in response to the Request for Information dated June 12, 2017.

Cancer patients need access to health insurance that will cover and reimburse all elements of multi-disciplinary cancer care, and they require such coverage without interruption. Delays in care, inability to access specific therapies, or other shortfalls in access have a direct impact on health outcomes. Cancer patients have long been at risk of medical bankruptcy due to the cost of their care, and they require cost-sharing protections and out-of-pocket spending caps to avoid this financial fate. The Patient Protection & Affordable Care Act (ACA), through its pre-existing condition protections, community rating requirements, essential health benefits, and cost-sharing reductions, was a step toward providing cancer patients access to quality care without extreme financial toxicity. For many cancer survivors who did not have access to employment-based insurance prior to the enactment of the ACA and who were not Medicare-eligible, their lives have been changed by their ability to obtain insurance and access to care. The law needs some modifications and refinements, especially to ensure that there are plans offered in every county in the nation.

1. Empowering patients and promoting consumer choice.

The most effective means for promoting consumer choice is through the establishment of strong marketplaces where there are multiple offerings. This has been accomplished in a number of states, but there are limited choices in other states or counties. To strengthen the marketplaces and foster more plan choices, we urge several actions. Cost-sharing reductions should be funded, and questions about the future of these payments should be answered. The mandate for purchase of insurance should be enforced. Finally, funds for market stabilization should be made available in the form of payments to plan issuers with a sicker and more expensive than average pool of insured individuals.

It has been reported that cancer patients have had difficulties obtaining care at the institution or from the individual physician they prefer because of the network limits of their ACA insurance plans. We urge that there be consumer-friendly standards for appealing a denial of coverage for out-of-network care and that cost-sharing for out-of-network care be counted toward out-of-pocket maximums. The request for information is focused on the elimination of regulations. However, we urge that there be more oversight of out-of-network limitations, as this would protect consumer choice.

2. Stabilizing the individual, small group, and non-traditional health insurance markets.

As we suggest above, market stabilization payments should be authorized, cost-sharing reductions should be paid, and the mandate for purchase of insurance should be enforced. We do not believe that risk pools or other strategies that would segment the population into the healthy and the sick are advisable. Their result will be the destabilization of insurance markets. Cancer survivors know that they need insurance that is comprehensive and covers their needs. If essential health benefits are relaxed and skimpy plans are offered, cancer survivors who need more generous coverage may find that plans that meet their needs are too expensive.

3. Enhancing affordability.

Health care affordability for cancer patients is a complex matter. Cancer patients need affordable yet comprehensive insurance coverage, manageable deductibles, and reasonable cost-sharing responsibilities so that they can use their insurance for accessing care in a timely fashion. They also need the assurance that their insurance plans do not have yearly and lifetime spending limits. Affordable insurance is dependent on healthy insurance markets, as we have discussed above in recommending several measures to strengthen the ACA. We recommend that there be greater patient protections related to cost-sharing for prescription drugs. Many cancer drugs are considered specialty drugs and in some insurance plans are subject to significant cost-sharing requirements. These cost-sharing standards adversely affect patient choices for their care and may also negatively affect adherence with treatment recommendations. We suggest the development of stronger cost-sharing protections as standards for qualified health plans.

4. Affirming the traditional regulatory authority of the States in regulating the business of health insurance.

The request for information suggests that the ACA has impeded the regulatory authority of the states regarding health plans. We do not believe that the ACA has adversely affected the regulatory authority of the states. Instead, it is our view that the insurance protections of the ACA – pre-existing condition protections, community rating, essential health benefits, and elimination of lifetime and annual spending caps – have been a lifeline for cancer patients, protecting their access to care. The oversight of ACA qualified health plans should be a shared responsibility of the federal and state governments, with oversight based on ACA standards.

We appreciate the opportunity to share the perspective of cancer patients. We urge action to strengthen and stabilize the ACA, and we look forward to working with you and your team at CMS.

Sincerely,

Shelley Fuld Nasso, MPP
Chief Executive Officer

# # #

Download the letter here. [PDF] (Right-click, save as)

Related Posts

NCCS Joins 120 Patient, Provider, and Consumer Organizations to Oppose Medicaid Cuts and Funding Caps

87 Organizations Call on Congress to Protect Medicaid

Read more of our coverage on the attempts to repeal the ACA »

Read more NCCS Policy Comments »

Fotolia 23428619 S e1461260836640

NCCS Submits Comments on CMS Proposed ACA Market Stabilization Rule

/in , , , , , , , , , /by
NCCS submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed rule that is intended to “help stabilize the individual and small group markets.”

The Affordable Care Act (ACA) has provided health insurance coverage—and therefore access to health care—for many cancer survivors who were previously denied insurance coverage due to their preexisting condition. Individuals who in the past had to forgo or delay cancer treatment because of a lack of health insurance now have access to care, thanks to insurance they purchased through ACA exchanges. Additionally, cancer survivors, who previously had to sacrifice monitoring and treatment of the late and long-term effects of cancer and cancer treatment, can access care.

“Cancer patients and survivors do not need an incentive to pay their premiums and retain health insurance coverage. They are incentivized by the need for health care.”
– NCCS Comment Letter
We recognize that stresses and strains exist in some of the health insurance exchanges, resulting in consumers facing limited and unaffordable options in various locations. We understand that CMS has offered certain changes in the operation of the exchanges in an effort the agency suggests may stabilize the insurance market. However, we are concerned that several of the proposed reforms in this rule will in fact reduce health insurance enrollment and increase instability in the insurance market.

In our letter, we outlined our concerns with the proposed rule and the potential for reducing enrollment and access to coverage.

Read the full letter below or download here.

Fotolia 23428619 S e1461260836640

NCCS Comments on CMS’s Proposed Revisions to the 2017 Physician Fee Schedule

/in , , , , , , , , , , /by

NCCS submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed revisions to the 2017 Physician Fee Schedule. Our comments noted our support for the Oncology Care Model, but acknowledged that only a minority of cancer care providers and cancer patients will be part of this model. Therefore, changes to the fee-for-service system to foster patient-centeredness are needed to improve quality of cancer care for Medicare beneficiaries.

We supported some specific changes that CMS proposed to recognize the time spent outside the in-person office visit and to reduce the administrative burden associated with using chronic care management codes. We believe that in these proposals, CMS has balanced the needs of patients with the burden on providers, and that increased utilization of the chronic care management codes will enhance care planning and care management for Medicare beneficiaries with multiple chronic conditions, including many cancer survivors.

Additionally, NCCS supported the comments submitted by the Cancer Leadership Council, which made similar points about the need to reduce barriers to providing care management services and using the codes that would reimburse for these services.

Our full comment letter is reprinted below.

PDF Download: NCCS Comments to CMS on the proposed 2017 Physician Fee Schedule »

NCCS logo blue-yellow sm

September 6, 2016

Andy Slavitt
Acting Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Hubert H. Humphrey Building
200 Independence Avenue, SW
Washington, DC 20201

Re: CMS-1654-P, Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2017

Dear Mr. Slavitt:

The National Coalition for Cancer Survivorship (NCCS) is a national organization representing survivors of all types of cancer in efforts to foster patient-centered cancer care, including in the medical home setting. We have focused on several critical elements of the cancer care system in our efforts to improve the overall quality of care. We believe that patients should begin their cancer care experience with a shared decision-making process. We also consider patient-centeredness a core element of quality care.

We have lent our strong support to the Oncology Care Model demonstration project, which holds promise for the coordination of care across episodes of care as well as coordination among all cancer care providers. We are especially pleased that the Oncology Care Model includes cancer care planning as one of the elements of care that Oncology Care Model practices must include in their medical home model. Care planning as defined in the Oncology Care Model will encourage patients to consider the goals of their treatment and will foster shared decision-making. These elements of the care process hold promise of improving the “patient-centeredness” of cancer care. For all of these reasons, we believe Oncology Care Model is an important test of the medical home in cancer care. We look forward to its implementation and to evaluation of care that is provided in the model.

Despite our enthusiasm about the Oncology Care Model and the lessons that may be derived from this demonstration project and then replicated, we realize that only a minority of cancer care providers and a minority of cancer patients will be part of this model. We would like to see access to cancer care planning and coordination for patients whose care is reimbursed through the fee-for-service system. These services, as we have stressed above, are critical to fostering patient-centeredness. As a result, we have for years recommended that a new Medicare service for cancer care planning be established. We have offered that recommendation through comments on Physician Fee Schedule updates for previous calendar years and have pursued other actions to establish such a service for cancer patients.

We have in past years expressed our support for establishment of the Transitional Care Management Code, the Chronic Care Management Code, and the Advance Care Planning Code, because these new codes represent important steps toward more effective care management and the delivery of patient-centered care. At the same time, we have urged the establishment of a code that would be specifically targeted to cancer patients and would ensure cancer care planning and management.

Cancer patients would benefit from care planning and management across the continuum of care. However, we note two occasions when these services might be provided with the potential for substantially enhancing the quality of care. After diagnosis and at the time of treatment decision-making, care planning and management services can help to ensure that cancer patients with additional chronic conditions have access to well-planned and coordinated care – care that is coordinated through the episode of cancer care and care that is managed across all medical subspecialists providing care. At the completion of active treatment, cancer patients with additional chronic conditions face substantial challenges in the monitoring of their health status and the coordination of multi-disciplinary care. Cancer survivors may face risks of a wide range of possible late and long-term effects related to their cancer and care treatment, in addition to the challenges of other chronic conditions. Timely follow-up care may be necessary to address these late and long-term effects and ensure high quality of life for cancer survivors after their cancer treatment.

Ensuring the appropriate utilization of the chronic care management codes holds promise of boosting the overall quality of cancer care for Medicare beneficiaries.

Improving Payment Accuracy for Care Management and Patient-Centered Services

In the proposed rule, the Centers for Medicare & Medicaid Services (CMS) stated:

“In recent years, we have undertaken ongoing efforts to support primary care and patient-centered care management within the PFS as part of HHS’ broader efforts to achieve better care, smarter spending and healthier people through delivery system reform.”
We support, with some reservations, the following provisions of the proposed rule that seek to improve delivery of patient-centered care.

  • Recognizing CPT code 99358, for prolonged evaluation and management service before and/or after direct patient care, first hour, and CPT code 99359, prolonged evaluation and management service before and/or after direct patient care, each additional 30 minutes. We believe that these codes, which seek to recognize the resource costs related to time spent outside the in-person office visit to care for Medicare patients, may improve cancer treatment and cancer survivorship planning and management. We hope that these codes will be utilized by providers who are spending substantial time outside the in-person office visit related to the planning and management of cancer care. We have received feedback from cancer care providers that the resources necessary to plan active treatment and to map out survivorship care options are not adequately recognized in existing codes.

  • Reducing the administrative burden associating with the chronic care management codes to remove barriers to billing for these services. Although, as noted above, we saw promise in the chronic care codes in connection with cancer treatment planning and survivorship care, we understand that they have not been widely utilized by providers of cancer care. The feedback that we have received is consistent with the conclusions of CMS regarding possible underutilization of chronic care management services, based on the number of eligible Medicare beneficiaries.

    We understand that the original standards for utilization of the chronic care codes were intended to ensure the proper utilization of the codes and were also intended to offer certain protections to beneficiaries receiving chronic care management services. However, if the standards for the codes are resulting in underutilization, cancer patients are not seeing any benefits from the codes.

    We would not typically support the changes in the consent requirements, the 24/7 electronic access to care plans, or the reliance on fax transmission of care plans to patients. However, in this situation, we think that CMS has balanced the needs of patients against the burden on providers seeking to use the chronic care codes. If this balancing of interests achieves greater utilization of the chronic care codes – including for cancer patients and survivors – it will have been a patient-centered revision of the standards for the codes. We encourage CMS to carefully monitor the utilization of the codes and especially to ensure that that there are conversations between provider and patient supporting patient consent for chronic care services. Patient consent is important because of the cost-sharing requirements associated with chronic care services.

  • Establishing a new G-Code to improve payment for visits that are considered initiating visits for chronic care management services. We believe there is some promise that the G-Code for initiating services will eliminate the potential for the initiating visit requirement to impede access to chronic care management.

We appreciate the opportunity to comment on the calendar year 2017 Physician Fee Schedule update proposal. We commend the efforts of CMS to enhance care planning and management for Medicare beneficiaries, including those with multiple chronic conditions.

Sincerely,
Shelley Signature
Shelley Fuld Nasso, MPP
Chief Executive Officer

# # #

Read more NCCS Policy Comments »

Fotolia 23428619 S e1461260836640

NCCS Comments on Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) Proposed Rule

/in , , , , , , /by

NCCS submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed rule on the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Our comments focus on the role of consumers in identification, development, and endorsement of quality measures. As health care delivery and payment transition from a volume-based system, it is critically important that there be a constant focus on health care consumers. The transition to patient-centered care must be accomplished with the input of patients and caregivers.

Additionally, NCCS supported the comments submitted by the Cancer Leadership Council, which focused on the role of patients and patient advocates in improving quality measurement, fostering clinical practice improvement efforts, and evaluating and advancing alternative payment models. Finally, we supported the comments of the Consumer-Purchaser Alliance, which applaud CMS’s leadership in moving to value-based payments, directionally support CMS’s proposed implementation of MACRA, and offer suggestions to strengthen the Quality Payment Program.

Read the full comments below.

Read the NCCS Comments on the MACRA Proposed Rule
PDF Download
Read the CLC Comments on the MACRA Proposed Rule
PDF Download
Read the Consumer-Purchaser Alliance Comments on the MACRA Proposed Rule
PDF Download

Read more NCCS Policy Comments »

Fotolia 23428619 S e1461260836640

NCCS Joins Patient Advocates in Proposing Alternative Approach to CMS’ Part B Drug Payment Demonstration

/in , , , , , , , /by

NCCS joined with patient advocacy organizations in the Cancer Leadership Council (CLC) in submitting comments to the Centers for Medicare and Medicaid Services (CMS) on its proposed Part B drug payment demonstration project. Over many years, the CLC has advocated reforms in Medicare reimbursement for cancer care, to support the delivery of evidence-based care that honors the needs and wishes of cancer patients.

In our letter, we recommended that CMS consider implementing a centralized acquisition program in the first phase of the project. Despite the previous unsuccessful experience with the previous competitive acquisition program, we think it holds promise going forward. A centralized acquisition program, if it can be implemented successfully, could potentially address the concerns of providers and patients by ensuring access to part B drugs for cancer patients in practices of all sizes and structure and in all geographic locations.

For patients, the centralized acquisition program is attractive because it would address the ability of any provider to obtain all drugs and would ensure there are no economic barriers to prescribing the best drug for any patient. In addition, the competitive acquisition program eliminates the margin that exists in the average sales price (ASP)-based system and would provide for a clear comparison with the ASP-based payments that would be retained in some practices in the demonstration. These two options would permit an important evaluation of incentives for high value care.

Read the full letter below.

Download the letter [PDF]

Read more NCCS Policy Comments »

Take Action

Stovall Award

The Ellen L. Stovall Award for Innovation in Patient-Centered Cancer Care is a unique opportunity for patients and survivors to recognize pioneers who are transforming the cancer care system.

Join CPAT

The NCCS Cancer Policy & Advocacy Team (CPAT) is a program for survivors and caregivers to learn about pressing policy issues that affect quality cancer care in order to be engaged as advocates in public policy around the needs of cancer survivors.

Share Your Story

NCCS represents the millions of Americans who share a common experience – the survivorship experience – living with, through and beyond a cancer diagnosis.

STAY CONNECTED

Together we can improve cancer care for survivors! Sign up to be the first to know about cancer policy issues and ways to take action

National Coalition for Cancer Survivorship
8455 Colesville Road  |  Suite 930  |  Silver Spring, MD 20910
877-NCCS-YES  |  info@canceradvocacy.org
Privacy Policy  |  Terms and Conditions

Copyright © 1995-2020 by the National Coalition for Cancer Survivorship
National Coalition for Cancer Survivorship, NCCS, Cancer Survival Toolbox, and related Logos are registered in the United States as trademarks of the National Coalition for Cancer Survivorship.