NCCS Responds to CMS, Demands Flexibility With Alternative Payment Models

The National Coalition for Cancer Survivorship (NCCS) has submitted comments to CMS, providing feedback on the Merit-Based Incentive Payment System (MIPs) and Alternative Payment Models (APMs) proposed by CMS as it transitions toward value-based reimbursement.

NCCS is an advocacy organization founded by cancer survivors and represents the voice of cancer patients and survivors. The organizations strives to improve the quality of care and quality of life for this population by promoting policy changes via partnerships with payers, care providers, National Committee for Quality Assurance, and the Patient-Centered Outcomes Research Institute.

In a response letter to the CMS, NCCS has addressed the following concerns with CMS’ reform proposal:

1. APMs for Cancer Care

While agreeing that the patient-centered oncology medical home (PCOMH) is a true value-based APM, NCCS recommends that CMS should design a variation to PCOMH that caters to the needs and requirements of survivors who are not undergoing active treatment. “Just as PCOMH models have transformed active cancer treatment for certain populations of cancer patients, the PCOMH approach holds promise for transforming survivorship care,” they write in their letter.

While appreciating the complexity of developing physician reimbursement models that focus on specific patient populations, the letter makes the point that cancer survivors are an exponential population among Medicare beneficiaries—what with innovative and better treatment options and care regimens—which calls for efforts to design a mode flexible APM.

2. Clinical Practice Improvement Activities Performance

NCCS recommends that Medicare Access and CHIP Reauthorization Act should include cancer treatment planning and coordination as a subcategory under the clinical practice improvement category of MIPS. NCCS has been very actively working to establish a payment code for cancer care planning, so it’d be easier for cancer care providers to claim payment for the time they spend with their patient to develop a care plan, which they believe, can have a significant impact on patient outcomes. NCCS, in the letter, has recommended CMS to include the following elements in MIPS:

· Shared decision-making that considers treatment gals and outline all elements of active treatment and symptom management in a written plan

· Coordination of multidisciplinary cancer care

· Appropriate management of side effects of the treatments and symptoms of cancer.

Describing it as a process measure, NCCS believes cancer care providers can provide information on treatment planning and coordination. Patient input to this subcategory can be gained through a Consumer Assessment of Healthcare Providers and Systems or CAHPS item, they propose.

3. Resource Use

NCCS has urged CMS to be conscious of the rapid pace of innovation in the cancer drug development industry, and to consider this when measuring resource utilization. Highlighting the importance of molecular diagnostics and targeted treatments in improving outcomes, the letter highlights the need for a fair balance between healthcare utilization and patient access.

“A resource use measure that took molecular diagnosis into account might help to protect against both underutilization and overutilization of targeted treatments and encourage progress toward delivery of the right treatment to the right patient at the right time,” they write.