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ASCO’s Clinical Practice Committee (CPC) and State/Regional Affiliates teleconferenced on Thursday afternoon, March 3rd, to discuss changes in Medicare drug and practice expense reimbursement as legislated in the Medicare Prescription Drug, Improvement, and Modernization Act of 2004 (MMA) and proposed in the 2005 Medicare Physician Fee Schedule.
Dean Gesme, M.D., Chair, ASCO CPC, John Cox, M.D., Incoming Chair, ASCO CPC, Deborah Kamin, Ph.D. (and ASCO staff), and Terry Coleman, Esq. (ASCO Counsel) led the discussion.
Update
Coleman summarized CMS/Medicare’s proposed Competitive Acquisition Program (CAP). He reminded the Committee that comments are due by April 26th. CAP will be a voluntary program under which oncologists could decide to order all of their drugs from a vendor rather than seek reimbursement directly from Medicare. Several questions remain unresolved. Will CAP only be for oncology or for additional specialties or for all Medicare Part B drugs? There are difficult accounting/management issues. Physicians need to keep a record of each drug by prescription number and provide that number in their claim for drug administration reimbursement. There are also contractor-related financial issues (i.e., unused drug, denied claims, co-payment collection, and reimbursement is limited to ASP plus 6%). ASCO seeks input on additional issues to include in their comments to CMS.
Kamin summarized current MMA payment issues. IV pushes versus infusions of less than 30 minutes is a continuing point of discussion between ASCO and CMS. Unfortunately, a resolution has not yet been offered but CMS pledged to provide revised instructions “very soon”. ASCO has been informed that some manufacturers have raised their drug prices. Members should bring these price increases and their relation to ASP to ASCO’s attention. ASCO and CMS have begun discussions on pay for performance (P4P) and quality of care in the context of continuing the demonstration project in 2006. CMS is open to continuing this dialogue. Specifically, they seek to develop a platform for implementing P4P in office-based practices. Congress is also very interested in P4P. Both (and NCI) are interested in ASCO’s various quality initiatives (NCCQ and QOPI). These could form the basis for an additional demonstration project in 2006. ASCO and CMS (and NCI) will continue the dialogue with some expectation that a project may be announced in the 2006 Physician Fee Schedule (in July).
ASCO urgently needs members to complete its survey of drug prices in order to effectively advocate before Congress and CMS on the ASP issue. Go to www.asco.org and click on the Calculate Impact link. All data submitted is kept confidential.
ASCO’s Carrier Advisory Committee (CAC) webpage has been redesigned (and is available via the Public Policy link or directly at www.asco.org/cac). It now links directly to the CMS coverage database providing for the comprehensive search of all local carrier coverage LCDs/LMRPs. ASCO seeks issues/case studies (both challenging and successful) to discuss at the ASCO CAC meeting in June.
Coverage of off-label indications has not worked well over the past year or two given the lack of updated compendia, especially the USP DI. The management of USP DI has moved from a quasi-government autonomous organization to MicroMedex. The new USP DI is now up and running and new off-label indications are expected to be published soon.
Comments, Questions, & Answers
Where does ASCO stand on the new NCCN compendia that has been completed and is routinely updated? ASCO does not have a position per se on the NCCN compendia. ASCO may advocate on its behalf (i.e., to be included in the list of accepted compendia and/or to have Congress change the law). ASCO needs to review the publication prior to advocating for its acceptance.
Demonstration project forms find that patients are doing well since the data collected is not related to their actual treatment. Has CMS analyzed the data and will they conclude that oncologists do not have to deal with nausea/vomiting, fatigue, and pain? CMS recognizes that the current data collection effort is flawed, that there is no context of treatment provided in the current coding schema, and that an extension of the demonstration project into 2006 might address/correct this flaw.
Are any new codes for treatment planning or pharmaceutical supervision being proposed? Such codes are on ASCO’s agenda for the CPT Editorial Panel. However, such codes are also of interest to other specialists and this dilutes the argument for oncology specific codes.
If the demonstration projected is extended to 2006, would CMS be interested in a demonstration code to track on-time treatment in the context of CAP? An excellent suggestion that ASCO will consider when working with CMS on the quality and P4P issues.
The CAP would place additional management burdens on physicians. Are any additional fees/reimbursement contemplated for physicians managing CAP? ASCO has discussed this and will bring it up to the CPT Editorial Panel.
Are there HIPAA violations in the CAP contractor program? Contractors will need to be HIPAA compliant and CAP would be considered a healthcare operations and exempt from some compliance. However, patient data cannot be used for marketing purposes. ASCO will consider including HIPAA concerns it its comments on CAP.
Is CAP without additional reimbursement a violation of the Paperwork Reduction Act? Probably not, unless CMS did not properly account for the additional paper work burdens. And, this is not likely.
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