ASCO Provides CMS Recommendations on Revisions to Part D

The American Society of Clinical Oncology (ASCO) recommends that CMS guard patients with cancer from high out-of-pocket costs that will impede patient access to life-extending cancer drugs, according to the society’s comments regarding proposed financial revisions to the Medicare Prescription Drug Benefit Program (Part D).

“ASCO appreciates the Agency’s interest in evaluating the financial relationships between Part D stakeholders,” the society wrote in a letter to CMS. “As CMS weighs new policies it is imperative to also find ways to guard against instances where financial toxicity will impede patient access for cancer patients to life-saving and life-extending drugs.”

While cancer therapies have traditionally been covered by the Part B benefit and administered intravenously, the latest advancements in oncology have evolved treatments into orally administered drugs that fall under the Part D category.

ASCO is concerned that pharmacy benefit managers (PBMs) are interfering with the physician’s control over prescribing the patient an anticancer drug. The society finds that PBMs will make medical decisions without the physician’s recommendations regarding dosage amounts and often do not fill or approve the prescription in a timely matter. These miscommunications between health professionals ultimately affect the health of the patient and the efficiency of the treatment.

Several approaches are recommended by ASCO for Medicare to promote access to cancer therapies and avoid complications. High-value clinical pathways is one approach that will provide patient access to the right drug once CMS discovers mechanisms to promote the use of these pathways. Cancer patients should also be protected by Medicare from high-cost drugs to avoid nonadherence to life-extending drugs.

ASCO also urges CMS to explicitly allow Part D enrollees to have access to any oral oncology dispensing pharmacy of their choice. If limited, a patient’s ability to access anti-cancer drugs will be reduced and non-adherence will continue. CMS, ASCO believes, should allow all community oncology practices and hospital-based practices with on-site pharmacies be able to participate in Plan D. However, CMS should still regulate these pharmacies to ensure their practice is ethical and providing high-quality treatments to patients.

The society also recommends that cancer drugs to not be labeled as specialty tier as it will impose higher costs on the patients. CMS should also exempt diagnosed cancer patients from the Comprehensive Addiction and Recovery Act which is in place to protect at-risk beneficiaries. By exempting cancer patients, the necessary medication can be administered to alleviate pain at any time during treatment.

“ASCO applauds CMS for its efforts to advance the Part D program’s goal of promoting access to prescription drug therapies at an affordable cost to beneficiaries and urges the implementation of high-quality clinical pathways to promote access to the right drug, for the right patient, at the right time.”