As community cancer care providers who experience first-hand the challenges of providing quality cancer care, ACCC members are the best positioned to educate decision-makers on how coverage and reimbursement issues affect community oncology.
ACCC provides members with the information and resources needed to effectively advocate on the issues that are important to them. Together, we can positively influence the future of community oncology.
On December 4, 2020, the Pharmaceutical Research and Manufacturers of America (PhRMA), the Association of Community Cancer Centers (ACCC), the Global Colon Cancer Association (GCCA) and National Infusion Center Association (NICA) filed a lawsuit in the U.S. District Court for the District of Maryland asserting that the Most Favored Nation (MFN) Interim Final Rule exceeds the statutory authority provided to the Centers for Medicare and Medicaid Services, raises serious constitutional questions and improperly fails to follow required rulemaking procedures.
UPDATE: On January 13, 2021, a federal court agreed to a stay in the lawsuit filed by the Association of Community Cancer Centers (ACCC) and other organizations. ACCC’s challenge to the MFN Model has been placed on hold, by agreement with the government, because the government has decided to not appeal the preliminary injunction in the BIO/CLSA litigation that prevents CMS from implementing the model. The public comment period on the MFN Model interim final rule ends on Tuesday, January 26, 2021. Read More.
While the Association of Community Cancer Centers (ACCC) is pleased that CMS has issued a delay in the Radiation Oncology (RO) Model implementation date, we remain committed to helping programs and practices understand the financial impact of the model and to demonstrate to the Centers for Medicare & Medicaid Services (CMS) and Congressional champions the punitive nature of the payment methodology.
For those of you who have been identified as RO Model participants, Anne Hubbard, MBA, Director of Health Policy, ASTRO, has developed a Professional Component Payment Methodology Workbook and a Technical Component Payment Methodology Workbook. These workbooks are designed so that RO Model participants can determine their 2021 payment rates under the model and compare those rates with 2019 average payments for each disease site.
Click here for additional details from ASTRO on the workbooks and how you can support their advocacy efforts.
Read the ACCC Radiation Oncology Model Final Rule (CMS-5527-F) Comment Letter.
Read ACCC’s comments on the CMS Radiation Oncology Model final rule, and the implementation delay in this ACCCBuzz blog post.
New resources and reminders from CMS have been posted to help RO participants access and navigate the Radiation Oncology Administrative Portal (ROAP). For further instructions for registering for—and logging in—to ROAP, please access the ROAP User Manual or visit the RO Model FAQs page. If you have trouble accessing ROAP, please email CMMIForceSupport@cms.hhs.gov.
On December 3, CMS released an updated version of the FAQs to reflect recent changes, including revised dates of the first performance year.
Additionally, the RO Model Billing Webinar scheduled for December 4, 2020 has been postponed until January 13, 2021. The call-in information for the webinar can be found here. If your questions are not answered in the FAQs, please send them to RadiationTherapy@cms.hhs.gov.
Access the webinar recording, slides, comment letters, and summaries of the proposed rules on the ACCC eLearning portal.
View Proposed Rules Resources
ACCC members can download an in-depth analysis of the proposed calendar year 2021 Medicare payment rules, prepared by Teri Bedard, RT(R)(T), CPC, Executive Director, Client & Corporate Resources, Coding Strategies, Inc.
Download Proposed Rules Analysis
These resources are available to ACCC members as one valuable benefit of membership. Please login with your ACCC credentials to access these resources in the ACCC eLearning Portal.
On August 4, 2020, the Centers for Medicare & Medicaid Reimbursement (CMS) issued the calendar year (CY) 2021
Physician Fee Schedule (PFS) and Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center Payment Proposed Rule (CMS-1736-P). ACCC and council are reviewing these proposed rules and will be providing comments.
Until this analysis is complete, read the proposed OPPS rule and the proposed PFS rule. Then watch the on-demand webcast on The 2021 Proposed PFS and OPPS Rules: Practical Implications and Considerations to gain insight into how these proposed rules will affect your cancer program.
On Nov. 1, 2019, the Center for Medicare and Medicaid Innovation (the Innovation Center) released an informal Request for Information (RFI), on value-based payment to support high-quality oncology care, specifically the Innovation Center's draft Oncology Care First (OCF) Model.
CMMI solicited comments on its conceptualization of the OCF as a potential successor to the Oncology Care Model (OCM) during a Nov. 4 Public Listening Session. The Innovation Center invited written feedback on its OCF Model, with a comment deadline of Dec. 13, 2019.
In response to the Innovation Center's request for information, the Association of Community Cancer Centers (ACCC) was pleased to submit comments on the potential Model. In its comment letter, ACCC applauds CMMI for making the OCF Model voluntary and conceptualizing the OCF as a multi-payer model, similar to Oncology Care Model. Expressing appreciation to the Innovation Center for the opportunity to comment on its proposals related to this important Model, ACCC urges that:
Read ACCC's comment letter.
ACCC members were invited to join legal experts and their ACCC colleagues for a one-hour overview and discussion about the Centers for Medicare & Medicaid Services (CMS) final CY 2020 OPPS and PFS rules. The webinar covered key proposals the agency has finalized under the OPPS that will affect next year’s payments for 340B hospitals, excepted off-campus provider-based departments (PBDs), as well as updates to the administration's pricing transparency and drug pricing reform efforts. A recording of this webinar, presentation slides, and rule summaries are available to ACCC members.
ACCC members can access summaries of the final rules here. [Requires Login] Also available, a summary of selected provisions of the CY2020 Hospital Price Transparency Requirements for Hospitals to Make Standard Charges Public final rule. (Requires Login)
View On-Demand Webinar Replay (Requires Login)
On Friday, September 27, the Association of Community Cancer Centers (ACCC) provided comments to the Centers for Medicare & Medicaid Services (CMS) on the agency's proposed calendar year 2020 Outpatient Prospective Payment System (OPPS) and Physician Fee Schedule (PFS) rules.
CMS is expected to release the final CY 2020 Medicare payment rules in early November.
Read ACCC's comments to the proposed CY 2020 OPPS rule.
Read ACCC's comments to the proposed CY 2020 PFS rule.
ACCC members joined legal experts and colleagues for a one-hour overview and discussion about the Centers for Medicare & Medicaid Services (CMS) proposed CY 2020 OPPS and PFS rules. The webinar covered proposals the agency introduced under the OPPS and PFS. A recording of the webinar and related materials are available to ACCC members.
Access the webinar replay, slides and ACCC's in-depth summaries of the proposed rules (Requires Login)
On August 7, the Centers for Medicare & Medicaid Services (CMS) released the finalized National Coverage Determination for FDA-approved Chimeric Antigen Receptor T-cell (CAR T-cell) Therapy. FDA-approved CAR T-cell therapies are approved to treat some people with specific types of cancer – certain types of non-Hodgkin lymphoma and B-cell precursor acute lymphoblastic leukemia.
Medicare will cover CAR T-cell therapies when they are provided in healthcare facilities enrolled in the FDA risk evaluation and mitigation strategies (REMS) for FDA-approved indications (according to the FDA-approved label). In addition, Medicare will cover FDA-approved CAR T-cell therapies for off-label uses that are recommended by CMS-approved compendia.
The NCD continues coverage for routine costs in clinical trials that use CAR T-cell therapy as an investigational agent that meet the requirements listed in NCD 310.1.
In announcing the NCD, CMS notes that outcomes data for CAR T-cell therapy in the Medicare population are "relatively limited," and states that "CMS will leverage information obtained from the FDA’s required post-approval safety studies for CAR T-cell therapies to the fullest extent possible."
Read the CMS Decision Memo
On Friday, February 15, the Center for Medicare & Medicaid Services (CMS) released a proposed national coverage determination (NCD) to provide nationwide consistency in coverage of FDA-approved CAR T-cell therapy under “Coverage with Evidence Development” (CED). Currently, nationwide coverage policy is not available for approved CAR-T therapies, and it has been covered at the discretion of local Medicare Administration Contractors (MACs) until now.
With this proposed NCD, CMS would require Medicare to cover the therapy when offered to patients “in a CMS-approved registry or clinical study, in which patients are monitored for at least two years post-treatment.” Information generated from these registries would aid CMS in identification of future patients for CAR-T therapies and better inform future coverage determinations in which the therapy could be covered “with no registry or trial requirement.”
The proposed decision is open for public comments until Mar. 17, 2019. A final decision is expected by May 17, 2019. Until the final decision is released, local Medicare Administrative Contractors (MACs) will continue to decide whether to cover these therapies.
Read CMS's Proposed NCDRead ACCC Summary [requires login]
On Monday, November 26, 2018, the Trump Administration issued another year-end follow-up to drug pricing reform efforts with the release of the Contract Year (CY) 2020 Medicare Advantage (MA) and Part D Drug Pricing Proposed Rule.
The Association of Community Cancer Centers (ACCC) is deeply concerned about the broad impact of the proposal on the nation's cancer care delivery infrastructure and particularly on those cancer programs and practices that see a high percentage of Medicare, Medicare only, and dual eligible patients.
Read ACCC's Policy StatementACCC Joins in Coalition Letter
The Association of Community Cancer Centers (ACCC) joined with more than 60 stakeholder organizations in a January 31, 2019, letter to CMS Administrator Seema Verma expressing concern about the Centers for Medicare & Medicaid Services (CMS) implementation of the National Coverage Determination (NCD) for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer. Specifically, the letter calls attention to the new interpretation of the NCD, which stakeholders believe will restrict patient access to medically necessary and relevant testing of germline mutations in patients with cancer and adversely impact patient care and outcomes.
Read the Letter
In October, the Trump Administration released of a three-pronged proposal to overhaul Medicare Part B and tackle rising drug costs. ACCC looks forward to commenting on this proposal, but the Administration's actions are still in the nascent stages of development. An Advance Notice of Proposed Rulemaking (ANPRM) was released on October 25, with expectation that a formal proposed rule would be released in Spring 2019. Many questions are yet to be addressed regarding the intricacies in implementation of this model.
Under the proposal the Medicare Part B landscape would change significantly through the use of a mandatory demonstration through the Center for Medicare and Medicaid Innovation (CMMI) with an International Pricing Index (IPI) model.
ACCC has expressed overarching concerns about the impact the proposal would have on the entire cancer care delivery infrastructure and, in particular, those programs and practices that see a high percentage of Medicare, Medicare only, and dual-eligible patients.
As ACCC urges policymakers to be aware of the effect this demonstration would have on the oncology community, we invite you to hear from ACCC and our legal experts at Hogan Lovells to learn more about this proposed model and what it could mean for your cancer program and your patients.
View On-Demand Webinar, Rule Summary and Slides (requires login)
Join ACCC and legal experts from Hogan Lovells for a one-hour overview and in-depth discussion about the Centers for Medicare & Medicaid Services (CMS) Final CY 2019 Outpatient Prospective Payment System (OPPS) and Mediciare Physician Fee Schedule (PFS) rules. The agency finalized several significant proposals this year and beyond that will impact payments to Evaluation & Management (E/M) visits, 340B hospitals and outpatient facilities, telehealth, as well as access for biosimilars, and much more. ACCC members are invited to dial in to find out how the final 2019 payment rules will affect your cancer program.
CMS Final CY 2019 Outpatient Prospective Payment System (OPPS) & Physician Fee Schedule (PFS) Rules: What You Need to Know
View On-Demand Webinar & Rule Summaries (requires login)
On Thursday, October 25, 2018, the Trump Administration released of a three-pronged proposal to overhaul Medicare Part B and tackle rising drug costs. ACCC looks forward to commenting on this proposal, but the Administration's actions are still in the nascent stages of development. An Advance Notice of Proposed Rulemaking (ANPRM) was released on October 25, with expectation that a formal proposed rule would be released in Spring 2019. Many questions are yet to be addressed regarding the intricacies in implementation of this model.
In a policy statement, the Association of Community Cancer Centers (ACCC) expresses overarching concerns about the impact of the proposal on the entire cancer care delivery infrastructure and, in particular, those programs and practices that see a high percentage of Medicare, Medicare only, and dual-eligible patients. ACCC urges policymakers to be aware that this policy has the potential to drastically hamper access to vital patient care and harm innovation for cancer care treatment.
ACCC looks forward to working with the Centers for Medicare & Medicaid Services (CMS) to ensure that any model put forth to the public is voluntary, maintains appropriate safeguards for access to patient care, and drives increased value-based propositions for the oncology community.
On September 24, 2018, the Association of Community Cancer Centers (ACCC) submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the agency's proposed CY 2019 Outpatient Prospective Payment System (OPPS) rule.
In its comments, ACCC recommends that CMS:
Read full comment letter here.
Read ACCC's CY 2019 OPPS proposed rule summary (requires login).
On September 10, 2018, the Association of Community Cancer Centers (ACCC) submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the agency's proposed Physician Fee Schedule rule for calendar year 2019.
Read the ACCC CY 2019 PFS comment letter.
Read ACCC’s CY 2019 PFS proposed rule summary and ACCC’s CY 2019 OPPS proposed rule summary (requires login).
The ACCC Alternative Payment Model Coalition builds off ACCC’s past Oncology Care Model Collaborative by addressing the broader interest in alternative payment models (APMs) beyond the OCM. This initiative will focus on addressing concerns about lack of preparedness to perform under these payment models, patient and provider access to the latest treatments, infrastructure, and long-term sustainability. This will be inclusive of medical, radiation, and surgical oncology and all respective APMs.