ASCO Submits Comments on the Proposed Medicare Physician Fee Schedule Rules

In July this year, CMS made public proposed policy changes to the Medicare Physician Fee Schedule (PFS) with updates on payment policies, payment rates, and quality provisions. These are the first set of proposed changes after the Sustainable Growth Rate repeal and include important changes to the Physician Quality Reporting System, the Physician Value-Based Payment Modifier, and the Medicare Electronic Health Record Incentive Program.

In response to the proposed changes, the American Society of Clinical Oncology (ASCO)—in a letter submitted to CMS at the end of the public comment period—suggests that CMS should “reconsider revisions to payment policies that could be administratively burdensome to oncology practices and result in reimbursement that inadequately supports optimal cancer patient care.”

While agreeing with some of the policy changes, ASCO has drawn attention to certain provisions that would impact patient care, physician payment, and quality of care. The following are concerns and recommendations by the organization:

1. “Incident” to Billing. ASCO recommends that CMS should not implement its proposal to change the incident to rules without clarifying that the ordering physician may differ from the supervising physician for chemotherapy administration.

2. Potentially Misvalued Codes. ASCO recommends that CMS should use methodologies other than the "high expenditure by specialty screen" to identify potentially misvalued codes.

3. Cancer Staging Measure. ASCO recommends that CMS should not finalize its proposal to eliminate the cancer staging measure from registry reporting in the Physician Quality Reporting System. ASCO urges CMS to retain this measure and consider refining the measure to apply only to a period of time following the initial office visit.

4. Chronic Care Management. ASCO recommends that chronic care management services have the potential to provide meaningful opportunities to improve oncology care management and lower Medicare's overall expenditures. CMS should continue to focus resources on providing beneficiaries with access to medical advice and eliminating counterproductive administrative burdens on providers that hamper patient access.

Additionally, ASCO has recommended CMS to reconsider the valuation of radiation oncology services to allow continued patient access to those services, particularly in the community clinics. For biosimilar products, ASCO has proposed fair and adequate reimbursement by CMS to allow patient access to these biologicals at lower cost.

In the letter, ASCO applauds the CMS proposal to provide reimbursement for advance care planning, with the flexibility of seeking advice from multiple providers. ASCO has recommended that CMS should establish new codes and payments for cognitive services performed in oncology care, which the CMS has recognized as an important task performed by specialists who care for certain subsets of Medicare beneficiaries. Other suggestions address tailoring quality and value measures for oncology and implementing alternate payment models to improve quality while reducing cost of care.