ACCC Expresses Concerns to CMS on 2010 Proposed Rules
ACCC Submits Comments on 2010 Proposed OPPS Rule and Physician Fee Schedule
ROCKVILLE, MD – September 2, 2009 - The Association of Community Cancer Centers (ACCC) submitted official comments to the Centers for Medicare and Medicaid Services (CMS) regarding revisions to the hospital outpatient prospective payment system (OPPS) and the Physician Fee Schedule.
In response to Medicare’s proposed 2010 OPPS rule published in the Federal Register on July 20, 2009, ACCC expressed concerns to CMS that the payment rate under the OPPS is not sufficient to cover the cost of many oncology drugs and the related pharmacy overhead services costs. Under the OPPS, CMS proposes to continue payment for separately payable drugs without pass-through status at average sales price (ASP) plus four percent in 2010. ACCC urged CMS to protect cancer patients’ access to quality care in the most appropriate setting by providing appropriate reimbursement for cancer treatments under the OPPS. Specifically, ACCC urged CMS to pay at least ASP plus 6 percent for the acquisition cost of separately payable drugs and to make an appropriate adjustment for pharmacy overhead.
Included in a list of recommendations, ACCC also urged Medicare to clarify its interpretation of the physician supervision requirements. CMS proposes to define “direct supervision” for on-campus hospital outpatient services to mean that the physician or nonphysician practitioner must be present in the hospital or on-campus provider-based department of the hospital and immediately available to furnish assistance and direction through the performance of the procedure. This proposal is in contrast to the current definition that requires the physician to be present in the on-campus provider-based department.
With regard to the proposed 2010 Physician Fee Schedule, ACCC expressed concerns about an expected 21.5 percent reduction in payment rates. Both medical and radiation oncologists face substantial reimbursement cuts. ACCC is very concerned about the effect of these cuts on physicians’ ability to respond to the growing need for their services and the associated threat to patient access to care. ACCC urged CMS to phase in the new rates over at least four years in order to give CMS the time to work with affected specialty societies to collect additional details and refine the data as necessary to ensure that it accurately reflects practice expenses.
Additionally, ACCC recommended that CMS not implement the proposed increase in the equipment utilization rate for equipment priced over $1 million and eliminate its proposal to replace consultation codes with other initial visit codes.
Since 1974, the Association of Community Cancer Centers (ACCC) has served as the leading national multidisciplinary organization that sets the standard for quality care for patients with cancer. ACCC is dedicated to promoting professional learning opportunities and to providing a forum for members to network and enhance their skills in the business, clinical and management aspects of care for the cancer community. Nearly 17,000 cancer care professionals from approximately 900 hospitals and more than 1,200 private practices are affiliated with ACCC. Our unique membership includes all members of the cancer care team: medical and radiation oncologists, surgeons, cancer program administrators and medical directors, pharmacists, oncology nurses, oncology social workers, and cancer program data managers. For more information, visit ACCC's website at www.accc-cancer.org. Follow us on Facebook and on ACCCBuzz, ACCC's online blog, www.acccbuzz.wordpress.com.
