Julie M. Vose, MD
The Merit-Based Incentive Payment System (MIPS) and the Advanced Alternative Payment Models (APM) announced earlier this year should not constrain physicians from self-driven innovation or deprive them of evaluation by generally accepted tools of performance measurement, ASCO told the CMS in a formal letter this month.
The response to the CMS plan for improving both the cost and quality of oncology care in the United States follows the enactment last spring of the Medical Access and CHIP Reauthorization Act (MACRA), which was designed to reform the fee-for-service system of healthcare reimbursement. MIPS and APMs formulated under the CMS plan introduce a system of performance incentives based on financial rewards and penalties.
Starting in July of this year, physicians received a 0.5% Medicare payment increase. Next year through 2019, Medicare physician payments increase 0.5% yearly under the plan. Other payments and bonuses can be varied according to physician performance.
ASCO’s response comes roughly seven months after the enactment of MACRA and it stresses that ASCO would like CMS to work collaboratively with the 35,000-member association of hematologists and oncologists in developing and implementing these value-driven programs.
“MACRA is an important opportunity for CMS and ASCO to work together to create a fair and sustainable reimbursement system for clinical oncology that serves the best interests of Medicare beneficiaries and the Medicare program,” said ASCO President Julie M. Vose, MD, in the response letter.
“As CMS works to transform the Medicare physician reimbursement system, we provided—and will continue to provide—the agency with robust feedback based on what we’ve learned over many years from ASCO’s payment reform efforts,” Vose said.
Other cancer associations also have weighed in on the MACRA changes, among them the Community Oncology Alliance, which is promoting its own version of APM that it would like to see made available to physicians, and which it prefers to what CMS has offered. The group has found support in US Representative Cathy McMorris Rodgers for HR1934, the Oncology Medical Home Pilot Bill, which COA Vice President Jeffrey Vacirca describes as a “true pilot program in terms of measuring patient care as well as cost of that care.”
In a press release, ASCO described its response as a collection of 11 overarching principles and detailed guidance for CMS as it moves forward with MIPS and APMs.
Among that guidance, ASCO references its longstanding position that CMS allow physicians to experiment with different models of care delivery as long as those meet the objectives of value that CMS is striving for. ASCO calls for “multiple APMs focused on clinical oncology to permit oncologists to select a model that is patient-centered and that meets the challenges facing their patients, practice, and community.”
Physicians under MACRA have a choice of participating in a MIPS program for incentivized value care or joining an APM that, while representing a restructure of their business model, may reduce the amount of risk exposure they would face under MIPS.
In its response, ASCO expresses a concern that physicians who enter the MIPS program will be given sufficient means to transition out of the MIPS program and into an APM should they choose to do so.
ASCO also expresses concern that the type of health reporting information required of doctors be meaningful and that physicians be allowed to rely on qualified data registries such as ASCO’s own Qualified Oncology Practice Initiative (QOPI), a “big data” initiative launched by ASCO to provide sweeping access to clinical trials data and therapy outcomes. In tandem with that, ASCO has called upon CMS to help cap the practice of “information blocking,” which comes in such forms as individual entities fully restricting access to health information or assessing fees for its use.
ASCO has previously looked warily at MIPS performance incentives, which can amount to financial penalties in the form of reduced compensation that could potentially make it harder for a practice to meet performance standards. In its response letter, ASCO calls for “a risk adjustment methodology that is specific to cancer treatment to ensure that financial incentives do not exacerbate disparities in patient access to high-quality, high-value cancer care.”
Oncologists also should be “held accountable under resource use measurements primarily for expenditures that are under their care,” ASCO said.
Other points are as follows:
Resource consumption should not be a basis for penalty when oncologists are delivering high-quality care.
Oncologists should be allowed to select “concordance with nationally recognized evidence-based, value-based clinical pathways in lieu of tracking resource use due to drug utilization under Medicare Part B and Part D.”
Existing audit tools be permitted for use under MIPS and APMs to facilitate meaningful improvements in cancer care.
Avoid hindering access to clinical trials through the implementation of MIPS and APMs.
Avoid the creation of administrative burdens and unfunded mandates that interfere with delivery of high-quality cancer care.
“Treating cancer is complex, nuanced and must evolve quickly to respond to advances in research and treatment, as well as the coordinated care and management that patients require,” said Philip J. Stella, MD, chair of the ASCO Government Relations Committee. “To ensure that MACRA is implemented in a sustainable manner, we urge CMS to work with ASCO and the oncology community to ensure that agency policies reflect the current realities of providing high-quality care to patients with cancer.