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IOS Federal Advocacy Issues

IOS remains vigilant about educating Congress on issues impacting the provision of cancer care. Here is an update on the recent conversations IOS has had with policymakers:


IOS Submits Comments to CMS on the Proposed 2018 Physician Fee Schedule Rule

On September 11, IOS submitted comments on the proposed rule published by the Centers for Medicare & Medicaid Services (CMS) related to payment policies under the Physician Fee Schedule (PFS) and other revisions to Part B for Calendar Year (CY) 2018.

Read the letter to CMS here.

September 12, 2017


ACCC Holds Webinar to Review CMS Proposed Changes

ACCC held a webinar on Wednesday, August 9, with Hogan Lovells to review CMS’ 2018 Proposed Rules for the Outpatient Prospective Payment System (OPPS) and Medicare Physician Fee Schedule (PFS).

Please utilize your MyNetwork log-in to access the slides and proposed rule summaries here.

August 11, 2017


IOS Urges CMS to Withdraw Part B Drug Payment Model From Consideration

As many of you know, in early March, CMS proposed a program that would have a detrimental impact on our ability to provide high quality cancer care to our patients. The Medicare Part B Drug Payment Model proposes a sweeping change to Part B reimbursement, and may be implemented as early as this fall.

The state society recently sent a letter on behalf of members to our elected officials to oppose CMS’ ill-conceived proposal.

Posted April 28, 2016


Call to Action: ACCC Strongly Opposes Proposed Part B Drug Payment Model

On April 5, ACCC held a members-only conference call providing an in-depth look at the proposed five year, two-phase demonstration project. Access a recording of the conference call and presentation slides here (log-in required).

Posted April 21, 2016


ACCC Comments on Proposed 2016 OPPS Rule

On August 31, 2015, ACCC provided comments to the Centers for Medicare & Medicaid Services (CMS) on the proposed 2016 Outpatient Prospective Payment System rule.

Read ACCC’s comment letter here.

Read the CMS fact sheet on the proposed rule here.

Download the proposed 2016 OPPS rule from the Federal Register here.

Listen to ACCC’s July 21, 2015 members-only conference call on the proposed 2016 OPPS rule and download ACCC analysis of the rule here (login reguired).

Posted September 1, 2015


Proposed 2016 Physician Fee Schedule Rule (PFS) and Hospital Outpatient Prospective Payment System (OPPS) rule

IOS and ACCC welcome your feedback on the 2016 proposed PFS and OPPS rules. Please contact to share your thoughts as we prepare our comments.

Background on the Rules: 

The Centers for Medicare & Medicaid Services (CMS) issued the proposed CY 2016 PFS rule on July 8, 2015. Comments will be accepted until Sept. 8, 2015.

The Centers for Medicare & Medicaid Services (CMS) issued the proposed 2016 OPPS rule on July 1, 2015. Comments will be accepted until Aug. 31, 2015.

Listen to a recording of the call and download the ACCC analysis of the proposed CY 2016 PFS rule here (login required).

Posted August 5, 2015


USP 800 – Hazardous Drug Safe Handling

IOS recently submitted comments on U.S. Pharmacopeia (USP) draft Chapter <800>, proposed standards for handling hazardous drugs in healthcare settings. Comments focused on the feasibility of several requirements, and suggest healthcare worker safety may be achieved through alternate less burdensome measures. USP has indicated that the earliest likely effective date for Chapter <800> is August 2016.

Posted June 24, 2015


SGR is Over: What Does it Mean for Providers?

By Maureen Leddy, Policy Coordinator, ACCC

On April 14, 2015, after years of uncertainty and 17 short-term “doc fix” patches to prevent severe annual cuts to physician payments, Congress approved H.R. 2, Medicare Access and CHIP Reauthorization Act (MACRA). This bipartisan, bicameral compromise finally puts an end to the sustainable growth rate (SGR) formula. MACRA provides physicians with the predictability in payments needed to continue to provide high-quality cancer care, while transitioning over a 10-year period to a new dual Medicare reimbursement system.

What’s in Store?

Under MACRA physicians must eventually participate in a Merit-Based Incentive Payment System (MIPS) or an Alternative Payment Model System. Through June 2015, MACRA calls for Medicare physician reimbursement at the rate set by last year’s “doc fix” patch. Then, for five years, through 2019, annual 0.5% increases to payment rates are established.

In 2020, a second five-year phase begins during which reimbursement rates remain flat. During this second phase, providers will need to transition to the Merit-Based or Alternative Payment Model Systems. Ultimately MACRA encourages providers to participate in Alternative Payment Model Systems through higher incentive payments; beginning in 2026, physicians will receive automatic payment updates of 0.75% if participating in an APM, and 0.25% if participating in MIPS, with an opportunity to receive additional bonus payments based on performance. Payments under the MIPS will be subject to positive or negative adjustments based on the following performance criteria:

During the second five-year phase through 2024, providers participating in an Alternative Payment Model will  be eligible for annual lump-sum bonuses equaling 5% of the prior year’s payments upon achieving specified targets in transitioning from fee-for-service payments.  Providers participating in MIPS will be eligible during this second five-year period for additional positive adjustments in rates for exceptional performance.

Payment Model Technical Advisory Committee

MACRA encourages the development of Alternative Payment Models applicable to specialties and small practices, as well as models that align private and state-based payers. The legislation calls for creation of a Payment Model Technical Advisory Committee that will recommend additional Alternative Payment Models to CMS. CMMI’s recently launched Oncology Care Model (OCM) already provides one venue for many cancer providers to participate in an Alternative Payment Model. Visit ACCC’s Oncology Care Model Resource Center for answers to providers’ questions on eligibility, reimbursement, and key considerations for participation in this new payment model, plus links to application forms and CMMI OCM materials.

Going forward, ACCC will be vigilantly monitoring the Payment Model Technical Advisory Committee recommendations for other Alternative Payment Models that may be relevant to oncology practices.

ACCC looks forward to working with our members to effectively implement the bill and transition towards a new future for physician reimbursement.

Posted April 29, 2015


ACCC Applauds Historic Vote Repealing Medicare's SGR

The Association of Community Cancer Centers (ACCC), of which IOS is a member, applauds the 92 Senators and 392 House members who voted “yes” on H.R. 2, the Medicare Access and CHIP Reauthorization Act of 2015. This bipartisan, bicameral compromise took remarkable leadership on both sides of the aisle and finally provides physicians with the predictable, appropriate payments they need to continue to provide high-quality cancer care.

"Last night’s historic 92-8 vote by the U.S. Senate is a long-awaited critical step in the right direction, restoring stability for physicians serving Medicare patients in communities across the country," said ACCC President Steven L. D’Amato, BSPharm, BCOP. "ACCC thanks the legislators in both houses who voted in support of SGR repeal. We also salute our ACCC members for their persistent, multi-year advocacy efforts on behalf of SGR reform."

In recent weeks, ACCC members were on Capitol Hill making more than 80 visits with congressional and committee staff as Congress negotiated the bill, and sent hundreds of letters to members of Congress urging support of H.R. 2.

After 13 years of uncertainty and 17 short-term "doc fix" patches to prevent severe annual cuts to physician payments, H.R. 2 finally brings an end to the Medicare sustainable growth rate (SGR) once and for all.

ACCC looks forward to working with our members to effectively implement the bill and transition towards a new future for physician reimbursement.

Posted April 16, 2015


CMS to Hold Provider Claims until April 15

The current "doc fix" patch to Medicare's sustainable growth rate (SGR) formula expired on March 31, 2015. In an April 1 notice, the Centers for Medicare & Medicaid Services (CMS) told providers that the agency is holding physicians' claims until April 15. CMS said the agency will notify providers on or before April 11 with more information.

CMS has also announced that the agency is delaying enforcement of the "two midnight" payment policy for short hospital stays until the end of April. This delay gives Congress time to pass the SGR repeal legislation when it reconvenes on April 13. The SGR repeal bill includes a six-month delay in enforcement of this payment rule. 

Source: Modern Healthcare

Posted April 2015


SGR Update

On March 26, by a vote of 392-37 the U.S. House of Representatives overwhelmingly passed H.R. 2, the Medicare Access and CHIP Reauthorization Act of 2015, legislation to permanently repeal and replace Medicare's sustainable growth rate (SGR) formula for physician reimbursement. Read a summary of the legislation here.

The White House expressed support for the bill on March 25.  The Senate is expected to consider the bill aftera two week Congressional recess.

IOS supports H.R. 2, which would create an improved physician payment system that rewards quality, efficiency, and innovation and put an end to the cycle of annual "doc fix" crises that have created uncertainty for millions of Medicare providers and beneficiaries for over a decade. As you well know, physicians need the assurance of predictable, appropriate payments in order to plan for the future and invest in the personnel and technologies that are essential to providing high-quality cancer care.

Contact Iowa’s Senators and ask them to support a permanent repeal of SGR. As an expert in cancer care, they need to hear from you!

Posted March 2015


CMS Releases Oncology Care Model

On February 12, the CMS Innovation Center (CMMI) released its Oncology Care Model (OCM) as part of a broader effort to lower healthcare costs and tie reimbursement to quality and value. Hospital-based practices and private physician-led practices that provide chemotherapy treatment are eligible to participate in this voluntary, five-year demonstration program.

Key facets of the model include:
•           Episode-based payment that targets chemotherapy and related care during a six-month period following the start of chemotherapy treatment.
•           Multi-payer design with Medicare fee-for-service and other payers working in tandem to promote care redesign for oncology patients.
•           Requiring physician practices to engage in practice transformation to improve quality and coordination of care.

The OCM model contains many positive elements, and ACCC, on behalf of IOS, continues our dialogue with CMS to clarify program details. We are seeking answers to member questions regarding the benchmarking methodology, specifics on the quality metrics and practice transformation requirements, eligibility to participate in the model, and more.

If your practice is interested in participating, or considering participation, we encourage you to submit a non-binding letter of intent to CMS by the deadline of May 7, 2015. We anticipate CMS will continue to provide additional guidance until the application deadline, which is June 18, 2015.

Oncology Care Model Letters of Intent: 
Practice - single location (PDF)  
Practice - multiple locations (PDF)

We welcome your questions and comments on this initiative.

Posted March 2015


After Hearing from IOS and Others, CMS Revokes Part D Proposed Changes

CMS recently proposed sweeping changes to the Medicare Part D program, including the elimination of at least 2 of the 6 drug classes of clinical concern, commonly referred to the 6 protected classes of drugs. 

IOS was quick to respond with comments urging CMS not to finalize this proposal.  Those comments can be found here.  Now, IOS is proud to announce that after hearing the concerns of our state society and other similar groups, CMS has decided to not move forward with its proposal. Thank you to everyone’s input on these comments. Please contact Sydney Abbott at if you have any questions.

Posted March 2014


IOS Submits Comments on the 2014 Proposed Physician Fee Schedule

IOS submitted comment to the Centers for Medicare and Medicaid Services (CMS) on the 2014 Proposed Physician Fee Schedule. Some of the IOS recommendations include asking CMS to:

You can view the CMS 2014 Proposed Physician Fee Schedule and the IOS Comments that were submitted by the September 6 deadline. To view the comments on, please use the tracking number: 1jx-87f5-paxz.

Posted September 2013


SGR Update! (HR 2810)

Issue: Physician reimbursement for Medicare is determined by the sustainable growth rate (SGR) formula. It is generally agreed the way this formula is calculated (tied to GDP spending targets) is fundamentally inappropriate for healthcare reimbursements. Congress has been looking at ways to fix the SGR formula for years but has faced a road block because of the enormous cost. This year, however, the Congressional Budget Office lowered the 10-year expected cost to fix the SGR from $245 billion to $138 billion—a bargain in congressional terms.

Legislation: On July 31 the House Energy and Commerce Committee voted unanimously in favor of a bill to replace the SGR formula. The Medicare Patient Access and Quality Improvement Act of 2013 (HR 2810), eliminates the current SGR formula and replaces it with a two-phase approach to physician reimbursement. Phase one stabilizes reimbursement with a 0.5% update to the Medicare fee schedule conversion factor annually for five years. Starting in 2019, phase two begins with 0.5% updates to the conversion factor. In phase two, these updates could be positive or negative—depending on the ability of an individual provider or group of providers to reach pre-determined quality measures or clinical improvement activities.

While IOS applauds the bill’s aim to replace the flawed SGR formula with stable payments and incentive updates, we are concerned that HR 2810 does not replenish the pool of available funds with savings realized annually by CMS. HR 2810 requires CMS to identify services it overpays and reduce those payments by 1% each year from 2016 to 2018 (RVU reductions). However, the bill contains no language calling for CMS to redirect that money back into services it designates as undervalued. Without this direction, it could mean that the total payment pool would be smaller and planned reimbursement increases might never materialize.

HR 2810 currently awaits a full floor vote with 40 bi-partisan co-sponsors. IOS will continue to work with legislators to ensure legislation passed appropriately reimburses physician services. IOS will keep members up to date on any developments.


Oral Parity (HR 1801)

Issue: An increasing percentage of the oncology development pipeline is made up of oral oncolytics, cancer therapies taken orally instead of tradition IV-infusions. Unfortunately, insurance coverage policy is not keeping up with this technology. When chemo is infused in the physician office setting, patients generally pay a co-pay of around $30. However, when a provider prescribes an oral therapy and the patient picks that up at their pharmacy, the patient is generally responsible for some percentage of the total cost of the drug. In the case of cancer, this can be thousands of dollars out of pocket for the patient every month. This leaves many patients unable to follow their treatment regimen.

Legislation: IOS has been a supporter or HR 1801, legislation that would require insurance companies to cover oral drugs at the same co-pay level as their IV counterparts. After meeting with the entire Iowa congressional delegation, Representatives Bruce Braley, Tom Latham, and David Loebsack signed on as co-sponsors in support of the bill.  Congratulations to IOS for garnering so much congressional support. However, we cannot slow down now; there is still a long way to go before this becomes law. 

IOS continues to identify additional House members to join the 49 cosponsors of HR 1801.  In addition, IOS is working with other stakeholders to identify a Senate champion to introduce legislation in the US Senate. IOS continues to communicate with Senators Grassley and Harkin on this front and will keep IOS members updated on further developments.


Cancer Drug Exemption from Sequester (HR 1416)

Issue: As part of the sequester, the Centers for Medicare and Medicaid Services (CMS) reduced Medicare reimbursement for all drugs and services by 2%. Providers are feeling the impact from the cuts and some are being forced to turn patients away. Cancer care providers are impacted disproportionally because of the way care is reimbursed. In addition to services, the 2% sequester cuts are applied to drugs, which have fixed costs. Given the high cost of cancer care therapies, the sequester is putting many cancer care providers under water.

Legislation: While it appears that the sequester is the “new normal,” legislation has been introduced in an attempt to make the cuts less oppressive for the oncology care community. HR 1416 would exempt cancer drugs from the 2% Medicare sequester. IOS has underscored the importance of passing this legislation to Iowa House members.  After meeting with Congressmen Bruce Braley, Tom Latham and David Loebsack, each member signed on as co-sponsors for this legislation. IOS now sets its sights on Congressman Steve King, the only remaining member of the Iowa delegation who has not become a co-sponsor. IOS continues to attend committee hearings and have conversations with legislators about the importance of exempting cancer drugs from the Medicare sequester.

On the Senate side where no bill has yet been introduced, IOS continues to urge Senators Grassley and Harkin to become champions. Both offices are reviewing the legislation. IOS will keep members updated on developments.


Coalition Work

While IOS works to maintain an impactful presence on Capitol Hill, it is important to note the other stakeholders standing with us. IOS and ACCC proudly stand with the Patient Equal Access Coalition (PEAC) to advance oral parity legislation, One Voice Against Cancer (OVAC) to preserve funding for cancer research, the Personalized Medicine Coalition, which supports advancements in molecular testing, and the ASP Coalition, which continually works hard to ensure adequate reimbursement for Medicare. The work of these partners raises the volume of cancer-care issues to Congress and IOS and ACCC are proud to advocate alongside our similar organizations on these issues.

Posted August 2013

For any questions regarding IOS’s federal advocacy activities, please contact:
Leah Ralph

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