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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.

 

 

Letters to Congress

Navigating Billing for Pharmacy Services


November 19, 2020
GettyImages-487727131

Integrating pharmacists into oncology care delivery models has shown to improve outcomes1 for patients and boost the financial stability of cancer programs and practices. But billing for pharmacy services can be onerous and complicated. In the latest installment of an ACCC webinar series marking American Pharmacists Month, experts discussed how to bill for pharmacists' services in chemotherapy management to accurately reflect the increasing role of pharmacists in oncology and enable those pharmacists to be adequately compensated for the services they provide.

Sandra Leal, PharmD, MPH, FAPhA, CDCES, executive vice president of theHealth Plans and Payers Business Unit for SinfoniaRx at Tabula Rasa Healthcare, and Bhavesh Shah, RPH, BCOP, senior director of specialty and hematology/oncology pharmacy at Boston Medical Center, joined moderator John Valgus, PharmD, MHA, BCOP, assistant director of the department of pharmacy at the University of North Carolina (UNC) Medical Center, on the expert panel.

Impact on Care

Pharmacists are integral to the patient-centered model of care at UNC, Dr. Valgus said, where its Comprehensive Oral Chemotherapy Program is depicted as a triad of three connected points--the clinical pharmacist practitioner, specialty pharmacy services, and the medical doctor--surrounding the patient to ensure the optimal benefit of chemotherapy.

In a study of the impact of pharmacist services on patient care, a leukemia pharmacist at UNC measured the impact of pharmacist intervention on patients with chronic myelogenous leukemia and measured the molecular response in those patients. He found that pharmacist intervention increased patient medication adherence from 52 percent to 74 percent. In addition, 92 percent of patients in the study were adherent to medication regimens, and they saw an improvement in response rates as a result.1

Navigating Billing Codes

Although the benefit of pharmacist intervention is clear, billing for pharmacist services has always been a challenge. At Tabula Rasa Healthcare, Dr. Leal works with the Health Plan and Payers Group to determine how best to use billing codes to account for the value-based care that pharmacists provide and thus justify having full-time pharmacists on staff.

“When we look at how to leverage current billing codes, we look at what’s already been done, and then at what’s coming down from CMS to determine what opportunities are presented there,” said Dr. Leal.

Many pharmacists have traditionally used the “incident to” model for reimbursement of their services. In this model, physicians bill for pharmacist services incident to their requests, rather than the pharmacist billing directly for their services under their own national provider identifier. Dr. Leal, who also serves as president-elect of the American Pharmacists Association (APhA), noted there has been some recent pushback on incident to billing, and she advocates for pharmacists having their own independent provider status. This would enable pharmacists to be more accurately compensated for the level of service they provide at the request of physicians.

Other codes that pharmacists have used to bill for their services include transitional care management codes, chronic care management codes, annual wellness visit codes, and diabetes self-management training (DSMT) codes. The pandemic has had some effect on the way pharmacists have been able to bill for their services. “With COVID, pharmacists were recognized to be able to deliver DSMT through telehealth and be recognized for that,” Dr. Leal said. “That’s very new and something that wasn’t approved before.”

Dr. Leal recommends reviewing the practice site-specific billing codes that are published by Pharmacy Today and are available online. Different practice settings have implications on what codes can be used by pharmacists, and understanding them can help pharmacists more accurately account for their services. Medicaid-specific codes within each state may also be used to account for the work of pharmacists. Although rules vary among states, much of what applies at federal-level rules also applies at the state level. Some states may have specific recognition or codes that enable pharmacists to bill at a higher level than Medicare codes.

Outside of coding for their services, there are several other mechanisms through which pharmacists can be compensated, including value-based contracting, direct patient payment models, drug discount programs, and commercial health payer billing methodologies. “Sometimes commercial health payers will contract with you to provide a certain intervention that might not be recognized by Medicaid or Medicare,” Dr. Leal said. “Looking at those direct value opportunities, a commercial payer might have a specific group or a population that they’re having a challenge with.”

Boston Medical Center

The limitations and complexities of pharmacy billing propelled Boston Medical Center to invest in finding a better way to bill for services in their setting. “Many codes that are out there have a lot of limitations,” Dr. Shah said. “For example, with chronic care management, you can only bill for it once a month per patient, so if a patient is seen more than once per month, you can’t get paid for it.”

The pharmacy team at Boston Medical Center worked with leadership and the finance department to create billing criteria that was customized to a pharmacist and easy to use. The criteria they developed is tied to the number of medications a patient is taking, combined with the level of complexity. For example, if a patient has multiple chronic diseases, the billing criteria level would increase.

The model was built into the medical center’s billing system, which enables the monitoring of the work of individual pharmacists to determine how much revenue they are generating. The compliance department conducts random audits to ensure the system is working as intended. “It pushed pharmacists to function as providers, because now they’re actually billing for each visit and each patient they’re seeing,” Dr. Shah said. This pharmacy billing and tracking model enables Boston Medical Center’s hematology/oncology pharmacy to determine how much revenue pharmacists are bringing in, and thus justify requests for additional full-time employees.

As the COVID-19 pandemic has illustrated, an evolving healthcare landscape demands new strategies and resources to bill for services. “When you’re thinking about future growth of pharmacy resources, it’s important to be able to tie the activity of current pharmacists to revenue that is coming in for your institution or from your practice,” Dr. Valgus said. “It’s also important to establish a role for pharmacy’s impact on the overall cancer program’s bottom line.”

The recorded webinar can be viewed upon registering for ACCC’s American Pharmacists Month webinar series. Other recorded webinars that can be viewed on demand include Closing the Oncology Research Gap, Pharmacy Metrics for Off-Label Treatment, and Pharmacists and Older Adults with Cancer: Effective Practices.

This webinar series is being offered through the ACCC Oncology Pharmacy Education Network (OPEN), established in 2004 to bring together education, resources, and peer-to-peer networking to help pharmacy professionals navigate the accelerating course of change in oncology—clinically, operationally, fiscally, and programmatically. ACCC thanks Merck & Co. for their financial support of the Oncology Pharmacy Education Network.

References

  1. Hughes TP, et al. Early molecular response predicts outcomes in patients with chronic myeloid leukemia in chronic phase treated with frontline nilotinib or imatinib. Blood. 2014;123(9):1353-60.

 

 

Enhancing Oncology Model

The Centers for Medicare & Medicaid Services (CMS) has announced a new, voluntary alternative payment model, the Enhancing Oncology Model (EOM), that will allow ACCC programs to improve care coordination and health outcomes for patients, as well as deliver high-quality and affordable cancer care to the communities they serve.
Learn More

Cancer Moonshot

Read ACCC's history with the Cancer Moonshot initiative and how we plan to continue to support the White House through resources and tools on cancer prevention for underserved and marginalized patient populations.
Read More

Advocacy News Releases

Featured Programs

The ACCC Alternative Payment Model Coalition addresses concerns about lack of preparedness to perform under Alternative Payment Models, patient and provider access to the latest treatments, infrastructure, and long-term sustainability.

The Oncology State Societies at ACCC Advocacy Engagement Pilot will establish a policy communication and learning infrastructure in nine states—Colorado, Louisiana, Missouri, New Mexico, New York, South Carolina, Texas, West Virginia, and Wisconsin—to address pressing policy issues that impact patient care and provider access. This work will focus on legislative efforts, standards of care, and health equity.

White Bagging

The Association of Community Cancer Centers and its Chapter Members from the Oncology State Societies at ACCC have developed resources for cancer care professionals to learn about the practice of white bagging, its deleterious effects on patient care, and how to take action against it.
View Resources

CMS Releases CY 2023 Medicare Payment Final Rules

On November 1, the Centers for Medicare and Medicaid Services (CMS) released the CY 2023 Medicare Physician Fee Schedule (PFS) and Hospital Outpatient Prospective Payment System (OPPS) Final Rules, finalizing the agency's new reimbursement policies taking effect January 1, 2023. ACCC will host a virtual in-depth review of these final rules and their anticipated impact on oncology programs and practices as part of our 2022 Oncology Reimbursement Meetings. Register for the upcoming webinar on December 13 and view the final rules and their corresponding CMS fact sheets below:
Webinar Registration

CY 2023 Medicare Payment Resource

This member-exclusive resource provides a high-level summary of Medicare coding and reimbursement policies finalized by the Centers for Medicare and Medicaid Services (CMS) in its calendar year (CY) 2023 rulemaking cycle. Highlights include Medicare policy changes included in the CY 2023 Medicare Physician Fee Schedule (MPFS) and Hospital Outpatient Prospective Payment System (HOPPS) final rules, including updates to the Medicare Quality Payment Program (QPP).

Download Resource (Member Login Required)

CY 2023 Medicare Proposed Rules Announced

On-Demand Webinar: The 2023 Medicare PFS and OPPS Proposed Rules: What You Need to Know

Learn about the key proposals in the CY 2023 Medicare Physician Fee Schedule (PFS) and Hospital Outpatient Prospective Payment System (OPPS) proposed rules and how these proposed changes to Medicare payment will impact oncology practices, freestanding cancer centers, and hospital-based cancer programs in 2023. There will be an opportunity for live Q&A.

Speakers: 
Teri Bedard, BA, RT(R)(T), CPC
Executive Director, Client & Corporate Resources
Revenue Cycle Coding Strategies, Inc

Matt Devino, MPH
Director, Cancer Care Delivery and Health Policy
Association of Community Cancer Centers
View On-Demand Recording

 

On July 7, CMS issued the (CY) 2023 Physician Fee Schedule (PFS) proposed rule, which would significantly expand access to behavioral health services, Accountable Care Organizations (ACOs), cancer screening, and dental care—particularly in rural and underserved areas.
Read the Letter  Fact Sheet

On July 15, CMS issues the (CY) 2023 Hospital Outpatient Prospective Payment System (OPPS) proposed rule. In addition to proposing payment rates, this year’s rule includes proposals that align with several key goals of the Administration, including advancing health equity in rural areas, promoting competition in the health care system, and promoting safe, effective, and patient-centered care. The proposed rule would further the agency’s commitment to strengthening Medicare and use the lessons learned from the COVID-19 PHE to inform the approach to quality measurement.
Read the Letter  Federal Register Download

 

ACCC Principles for Drug, Diagnostics, and Biomarker Reimbursement

ACCC believes that to improve the current treatment options available for patients at the lowest cost without decreasing access to care, the following four principles should be taken into consideration.

Any proposed changes in reimbursement for drugs, diagnostics, and biomarker testing should decrease health inequities and not negatively impact the ability of cancer programs and practices to provide necessary supportive care services for potentially disadvantaged patients.
Read the Principles

Cancer Buzz Podcasts

  • Live from NOC: ACCC Priorities for the President’s Cancer Panel - [MINI PODCAST]
    Oct 10, 2023

    ACCC was invited to share the association’s key priorities for impacting cancer care in the US. ACCC president Olalekan Ajayi, PharmD, MBA, and chief operating officer at Highlands Oncology Group, PA, discusses the meeting and these initiatives.

  • Combatting Caregiver Isolation Through Awareness and Education — [MINI PODCAST] EP 130
    Aug 29, 2023

    "Many caregivers have it together, they’re on top of everything. They are organized, they are experts at this, but they are falling apart inside. You aren’t going to know if you don’t ask."

  • Pharmacy Benefit Managers: How Advocacy Led to Action [PODCAST] Ep 85
    Jun 28, 2022

    Listen to ACCC's Matt Devino and President of the Empire State Hematology & Oncology Society, Rahul Seth, DO, discuss why every voice is critical in grassroots advocacy efforts on both the federal and state level, and how cancer professionals who moonlight as patient advocates can help improve access to care and reduce financial toxicity for people living with cancer.

  • [MINI-PODCAST] Ep 79: State Advocacy Matters
    Mar 22, 2022

    Learn how state oncology societies have the power to mobilize larger groups of providers across the state to make their voices heard on behalf of their patients—and how you can get involved.   

  • [PODCAST] Ep 73: Biomarker Testing Advocacy
    Dec 7, 2021

    Biomarker testing is crucial to precision medicine, but barriers still exist. Learn from two healthcare advocates about recent policy changes designed to ensure better access to biomarker testing.

  • [MINI-PODCAST] Ep 72: Genetic Counseling Advocacy
    Nov 30, 2021

    Hear from Colleen Campbell, PhD, MS, LGC, as she explains policy changes that can help patients access genetic counseling services, while also benefiting those who provide these services. 

  • [PODCAST] Ep 56: What Comes Next for Telehealth?
    Apr 27, 2021

    We'll discuss the telehealth regulatory and policy changes enacted during the COVID-19 pandemic, what may change in 2021, and what’s likely to remain the same regarding the reimbursement of remote care. 

Navigating Billing for Pharmacy Services


November 19, 2020
GettyImages-487727131

Integrating pharmacists into oncology care delivery models has shown to improve outcomes1 for patients and boost the financial stability of cancer programs and practices. But billing for pharmacy services can be onerous and complicated. In the latest installment of an ACCC webinar series marking American Pharmacists Month, experts discussed how to bill for pharmacists' services in chemotherapy management to accurately reflect the increasing role of pharmacists in oncology and enable those pharmacists to be adequately compensated for the services they provide.

Sandra Leal, PharmD, MPH, FAPhA, CDCES, executive vice president of theHealth Plans and Payers Business Unit for SinfoniaRx at Tabula Rasa Healthcare, and Bhavesh Shah, RPH, BCOP, senior director of specialty and hematology/oncology pharmacy at Boston Medical Center, joined moderator John Valgus, PharmD, MHA, BCOP, assistant director of the department of pharmacy at the University of North Carolina (UNC) Medical Center, on the expert panel.

Impact on Care

Pharmacists are integral to the patient-centered model of care at UNC, Dr. Valgus said, where its Comprehensive Oral Chemotherapy Program is depicted as a triad of three connected points--the clinical pharmacist practitioner, specialty pharmacy services, and the medical doctor--surrounding the patient to ensure the optimal benefit of chemotherapy.

In a study of the impact of pharmacist services on patient care, a leukemia pharmacist at UNC measured the impact of pharmacist intervention on patients with chronic myelogenous leukemia and measured the molecular response in those patients. He found that pharmacist intervention increased patient medication adherence from 52 percent to 74 percent. In addition, 92 percent of patients in the study were adherent to medication regimens, and they saw an improvement in response rates as a result.1

Navigating Billing Codes

Although the benefit of pharmacist intervention is clear, billing for pharmacist services has always been a challenge. At Tabula Rasa Healthcare, Dr. Leal works with the Health Plan and Payers Group to determine how best to use billing codes to account for the value-based care that pharmacists provide and thus justify having full-time pharmacists on staff.

“When we look at how to leverage current billing codes, we look at what’s already been done, and then at what’s coming down from CMS to determine what opportunities are presented there,” said Dr. Leal.

Many pharmacists have traditionally used the “incident to” model for reimbursement of their services. In this model, physicians bill for pharmacist services incident to their requests, rather than the pharmacist billing directly for their services under their own national provider identifier. Dr. Leal, who also serves as president-elect of the American Pharmacists Association (APhA), noted there has been some recent pushback on incident to billing, and she advocates for pharmacists having their own independent provider status. This would enable pharmacists to be more accurately compensated for the level of service they provide at the request of physicians.

Other codes that pharmacists have used to bill for their services include transitional care management codes, chronic care management codes, annual wellness visit codes, and diabetes self-management training (DSMT) codes. The pandemic has had some effect on the way pharmacists have been able to bill for their services. “With COVID, pharmacists were recognized to be able to deliver DSMT through telehealth and be recognized for that,” Dr. Leal said. “That’s very new and something that wasn’t approved before.”

Dr. Leal recommends reviewing the practice site-specific billing codes that are published by Pharmacy Today and are available online. Different practice settings have implications on what codes can be used by pharmacists, and understanding them can help pharmacists more accurately account for their services. Medicaid-specific codes within each state may also be used to account for the work of pharmacists. Although rules vary among states, much of what applies at federal-level rules also applies at the state level. Some states may have specific recognition or codes that enable pharmacists to bill at a higher level than Medicare codes.

Outside of coding for their services, there are several other mechanisms through which pharmacists can be compensated, including value-based contracting, direct patient payment models, drug discount programs, and commercial health payer billing methodologies. “Sometimes commercial health payers will contract with you to provide a certain intervention that might not be recognized by Medicaid or Medicare,” Dr. Leal said. “Looking at those direct value opportunities, a commercial payer might have a specific group or a population that they’re having a challenge with.”

Boston Medical Center

The limitations and complexities of pharmacy billing propelled Boston Medical Center to invest in finding a better way to bill for services in their setting. “Many codes that are out there have a lot of limitations,” Dr. Shah said. “For example, with chronic care management, you can only bill for it once a month per patient, so if a patient is seen more than once per month, you can’t get paid for it.”

The pharmacy team at Boston Medical Center worked with leadership and the finance department to create billing criteria that was customized to a pharmacist and easy to use. The criteria they developed is tied to the number of medications a patient is taking, combined with the level of complexity. For example, if a patient has multiple chronic diseases, the billing criteria level would increase.

The model was built into the medical center’s billing system, which enables the monitoring of the work of individual pharmacists to determine how much revenue they are generating. The compliance department conducts random audits to ensure the system is working as intended. “It pushed pharmacists to function as providers, because now they’re actually billing for each visit and each patient they’re seeing,” Dr. Shah said. This pharmacy billing and tracking model enables Boston Medical Center’s hematology/oncology pharmacy to determine how much revenue pharmacists are bringing in, and thus justify requests for additional full-time employees.

As the COVID-19 pandemic has illustrated, an evolving healthcare landscape demands new strategies and resources to bill for services. “When you’re thinking about future growth of pharmacy resources, it’s important to be able to tie the activity of current pharmacists to revenue that is coming in for your institution or from your practice,” Dr. Valgus said. “It’s also important to establish a role for pharmacy’s impact on the overall cancer program’s bottom line.”

The recorded webinar can be viewed upon registering for ACCC’s American Pharmacists Month webinar series. Other recorded webinars that can be viewed on demand include Closing the Oncology Research Gap, Pharmacy Metrics for Off-Label Treatment, and Pharmacists and Older Adults with Cancer: Effective Practices.

This webinar series is being offered through the ACCC Oncology Pharmacy Education Network (OPEN), established in 2004 to bring together education, resources, and peer-to-peer networking to help pharmacy professionals navigate the accelerating course of change in oncology—clinically, operationally, fiscally, and programmatically. ACCC thanks Merck & Co. for their financial support of the Oncology Pharmacy Education Network.

References

  1. Hughes TP, et al. Early molecular response predicts outcomes in patients with chronic myeloid leukemia in chronic phase treated with frontline nilotinib or imatinib. Blood. 2014;123(9):1353-60.