CANCER LEADERSHIP COUNCIL

Similar documents
CANCER LEADERSHIP COUNCIL

Comments on Request for Information on Specialty Practitioner Payment Model Opportunities

Submitted electronically:

Administrators. Medical Directors. 61% The negative impact on our hospital-based program s. 44% We will need to consider the most appropriate or most

Payer s Perspective on Clinical Pathways and Value-based Care

member entities, contribute information and perspectives regarding important healthh care decisions to a degree that has not been possible

Re: Medicare Program; Medicare Shared Savings Program: Accountable Care Organizations, Proposed rule.

ASCO s Payment Reform Model

CMS Oncology Care Model s Standards for Patient Navigation

The Influence of Health Policy on Clinical Practice. Dr. Kim Kuebler, DNP, APRN, ANP-BC Multiple Chronic Conditions Resource Center

PALLIATIVE CARE: CHARTING A COURSE MEETING OF THE PATIENT QUALITY OF LIFE COALITION FEBRUARY 18, 2015

Prior to implementation of the episode groups for use in resource measurement under MACRA, CMS should:

Patient Navigation Programs Leveraging Care Pathways. Tina Evans, RN, BS Director of Nursing,Onco-Nav

MEDICARE PART D MEDICATION THERAPY MANAGEMENT PROGRAM STANDARDIZED FORMAT

Re: 42 CFR Part 485; Medicare Program; Conditions of Participation (CoPs) for Community Mental Health Centers

April 9, The Honorable Alex Azar Secretary U.S. Department of Health & Human Services 200 Independence Avenue, S.W. Washington, D.C.

Future of Patient Safety and Healthcare Quality

Building the Oncology Medical Home John D. Sprandio, M.D., FACP Consultants in Medical Oncology & Hematology, P.C. Oncology Management Services, LLC

Oncology Home Care: A Strategy for Growth & Improved Clinical Performance. Our Story. What s So Special About Specialty Care?

Quality Measurement at the Interface of Health Care and Population Health

Domain 1 Patient Engagement

RE: Centers for Medicare & Medicaid Services: Innovation Center New Direction Request for Information (RFI)

The Development of the Oncology Symptom Management Clinic

Draft Covered California Delivery Reform Contract Provisions Comments Welcome and Encouraged

UnitedHealth Center for Health Reform & Modernization September 2014

Exhibit 1. Medicare Shared Savings Program: Year 1 Performance of Participating Accountable Care Organizations (2013)

2014 Chapter Leadership Workshop

Assignment of Medicare Fee-for-Service Beneficiaries

1875 Connecticut Avenue, NW, Suite 650 P Washington, DC F

1500 West Park Drive Suite 100 Westborough, MA (508) August 21, 2018

Rodney M. Wiseman, DO, FACOFP dist. ACOFP President

Health System Transformation. Discussion

Mental Health Liaison Group

Specialty Payment Model Opportunities Assessment and Design

Payment Reforms to Improve Care for Patients with Serious Illness

Bundled Payments. AMGA September 25, 2013 AGENDA. Who Are We. Our Business Challenge. Episode Process. Experience

Medicare Physician Fee Schedule. September 10, 2018

Accountable Care in Infusion Nursing. Hudson Health Plan. Mission Statement. for all people. INS National Academy of Infusion Therapy

National Coalition on Care Coordination (N3C) Care Coordination and the Role of the Aging Network. Monday, September 12, 2011

I. Coordinating Quality Strategies Across Managed Care Plans

Models for Patient-centered Cancer Care

Optimizing Operations through Data Collection and Dissemination. Raymond Belles, Jr. Managing Consultant

Information for patients with gynaecological cancer. Departments of gynaecology, oncology and gynaecological oncology

Integrating Population Health into Delivery System Reform

History of Patient Navigation 8/26/17. Cancer Navigation September 26, Agenda

Value based care: A system overhaul

Culture Change. Bryan J. Weiner, Ph.D.

RE: Medicare Program; Request for Information Regarding the Physician Self-Referral Law

The MetroHealth System

2125 Rayburn House Office Building 2322a Rayburn House Office Building Washington, D.C Washington, D.C

Re: CMS Medication Therapy Management Program Improvements

Thought Leadership Series White Paper The Journey to Population Health and Risk

December 22, Submitted via

Building the Oncology Medical Home. Susan Tofani, MS, Director Network and Payer Relations, Oncology Management Services, Inc.

Medicaid Efficiency and Cost-Containment Strategies

REPORT OF THE BOARD OF TRUSTEES

Drivers Towards Quality and Value

Path to Transformation Concept Paper Comments and Recommendations. Palliative Care Community Partners (PCCP)

ACOs: California Style

Getting Ready for the Post-SGR World. Presented by: Sybil R. Green, JD, RPh, MHA. West Virginia Oncology Society Spring Meeting May 5, 2016

TRENDS IN CANCER PROGRAMS

Risk Adjusted Diagnosis Coding:

Coordinated Care: Key to Successful Outcomes

Reinventing Health Care: Health System Transformation

ASCO s Payment Reform Model. Presenter John Hennessy Sarah Cannon

March 5, March 6, 2014

Alternative Managed Care Reimbursement Models

Centers for Medicare & Medicaid Services: Innovation Center New Direction

Radiation Oncology. This guide was prepared by the nursing staff of the JGH and the volunteers of Hope & Cope.

Seeing the Value and Transparency of Medicare Part B: Four Case Studies of Medicare Successes

Models of Accountable Care

September 22, 2017 VIA ELECTRONIC SUBMISSION

HEALTH CARE REFORM IN THE U.S.

Partnering with Hospice: Reducing Skilled Nursing Facility to Hospital Readmissions

DRAFT Optimal Care Pathway

National Council on Disability

September 11, 2017 REF: CMS-1676-P

Supportive Care Roundtable

Building & Strengthening Patient Centered Medical Homes in the Safety Net

Impact of Patient Navigation in an Integrated Care Delivery System

The Accountable Care Organization Specific Objectives

Accountable Care and Governance Challenges Under the Affordable Care Act

June 27, Dear Secretary Burwell and Acting Administrator Slavitt,

Barbara McAneny MD CEO, CEO New Mexico Cancer Center CEO, Innovative Oncology Business Solutions AMA Board of Trustees

REDESIGNING HEALTH CARE FROM THE BOTTOM UP INSTEAD OF FROM THE TOP DOWN

MIPS/APM Proposed Rule Summary On Monday, May 9, 2016 the Centers for Medicare and Medicaid Services (CMS) published in the Federal Register the

HOSPITALS & HEALTH SYSTEMS: DATA-DRIVEN STRATEGY FOR BUNDLED PAYMENT SUCCESS 4/19/2016. April 20, 2016

RE: Next steps for the Merit-Based Incentive Payment System (MIPS)

December 19, Dear Acting Administrator Slavitt:

Transforming to Value: One Way Forward

Accountable Care and Home Health: Opportunities for Innovation

The Diagnosis of Cancer and Financial Toxicity

Health System Transformation, CMS Priorities, and the Medicare Access and CHIP Reauthorization Act

Symptom Management? Complex cases? Difficult decisions?

How can oncology practices deliver better care? It starts with staying connected.

PHA 6276 Syllabus Pharmacy Benefit Design & Management Course

1. General description

Community Oncology Town Hall. Moderator John Cox, DO, FASCO

Overview of Quality Payment Program

Bridging to Preventive Care: The Roadmap to Medicaid Coverage of Community Based Chronic Disease Prevention & Management Programs. September 20, 2017

Transcription:

CANCER LEADERSHIP COUNCIL A PATIENT-CENTERED FORUM OF NATIONAL ADVOCACY ORGANIZATIONS ADDRESSING PUBLIC POLICY ISSUES IN CANCER April 10, 2014 Patrick Conway, M.D. Deputy Administrator for Innovation and Quality Chief Medical Officer Center for Medicare and Medicaid Innovation Centers for Medicare & Medicaid Services 7500 Security Boulevard Baltimore, Maryland 21244 Re: Mitre Corporation Technical Expert Panel for Specialty Payment Models Opportunities and Design Initiative and Request for Information on Specialty Practitioner Payment Model Opportunities Submitted via email at specialtypaymentreform@brookings.edu and to Centers for Medicare & Medicaid Services Dear Dr. Conway: The undersigned cancer patient, health professional, and research organizations submit these comments in response to the Request for Information on Specialty Practitioner Payment Model Opportunities and the work of Mitre Corporation and Brookings Institution related to oncology payment models. We are pleased that the Centers for Medicare & Medicaid Services is committed to evaluating oncology payment models and testing them consistent with Section 3021 of the Affordable Care Act, which authorizes the Center for Medicare and Medicaid Innovation and grants it the power to test innovative health care payment and service delivery models. We understand that the current payment reform efforts will focus on medical oncology services. Although that leaves many more elements of oncology care still to be addressed, focusing on medical oncology services represents an important step.

Elements of Quality Cancer Care In these comments, we share a patient-focused consensus statement identifying the elements of quality cancer care and then discuss the payment models (reviewed in the Brookings Institution environmental scan) that will foster the achievement of the standards we have articulated. Each cancer patient should be served by a cancer care system that: Provides care that is based on the best available evidence and consistent with practice guidelines developed through a trustworthy process; Begins with a cancer care planning process that incorporates shared decision-making and a discussion of treatment intent and treatment choices, presents options for symptom management and permits early access to palliative care according to patient preference, facilitates a discussion of clinical trials enrollment opportunities, considers fertility preservation, where appropriate, and triggers the coordination of multidisciplinary care; Fosters innovation in strategies for patient management of care and in patient-physician communication; Initiates care according to practice guidelines and without significant delay; Regularly assesses patient symptoms, including pain, performance status, diarrhea, nausea and vomiting, depression, distress, and neuropathy; Includes procedures and processes for response to patient questions and problems after regular office hours as well as response to email questions, especially during periods when chemotherapy is being administered; Provides adequate payment to permit the development of a multi-disciplinary cancer care team; Integrates all services and resources, including community-based services, necessary for post-treatment monitoring and care; Eliminates financial incentives that might favor one treatment choice or modality over another; Abandons a payment structure that rewards the volume of services provided; Eliminates cost-sharing structures that influence treatment choices in a significant way, causing patients to forgo treatments that are recommended and/or that are consistent with guidelines; and Measures the performance of the health delivery system by use of the best available quality measures and assesses patient and family satisfaction with the health system.

Specialty Payment Models that Will Advance Quality Cancer Care Although each of the payment models reviewed by Brookings Institution may have advantages, we are not persuaded that all of them will encourage or require clinical practice improvements critical to delivery of the quality care we describe above. For example, we understand that adherence to clinical pathways will encourage delivery of care according to clinical practice guidelines, an important goal for a cancer care system. However, adherence to clinical pathways will not transform the care delivery system. Neither will payments for episodes of care foster care improvement if the episodes are defined primarily by a period of time for delivery of care and not by specific elements of care. We are aware of the elements of a successful patient-centered medical home, as defined by the National Committee for Quality Assurance (NCQA). We have also monitored efforts to experiment with a patient-centered oncology medical home, and we see the promise of this model to standardize processes so that care is planned with patient input, patients are evaluated routinely, and care is provided according to the best evidence. The standardization of the processes of cancer care as fostered by the patient-centered oncology medical home will in turn permit the episode of medical oncology services or bundle of medical oncology services to be defined. Experts have identified a number of challenges to designing bundles and episodes of care, including the identification of the health care provider who will manage the episode/bundle and the services and goods that will be included in the bundle. These definitional and procedural challenges can be addressed in significant part by reference to the processes of patient-centered medical homes. The design and implementation of the patient-centered oncology medical home triggers the reform of the processes of care, and this new system of care could be financed by a bundle or episode of care payment system that would reflect in large part the elements of care in the medical home. Measurement of Cancer Care Quality in New Payment Models The transition from a fee-for-service reimbursement system that rewards the volume of services provided to payment models that reimburse for an episode or bundle of care represents a significant change for both medical oncologists and patients. It is important that such a system be carefully evaluated and its implementation consistently monitored. Although some are concerned that current cancer care quality measures are inadequate and the qualification process for new measures is too long, a core set of measures could be immediately used to evaluate the quality of care in a reformed system, even as additional quality measures are developed.

We recommend that these measures be utilized at the outset of implementation of a new delivery/payment system: A measure of delivery of chemotherapy according to National Comprehensive Cancer Network or other appropriate guideline, to ensure proper utilization and to protect against under-treatment as the payment system moves away from volume-based reimbursement and rewards; A measure to ensure that there has been a care planning discussion between patient and medical oncology team that reviews the intent of treatment and treatment choices; A measure of care team efforts to assess patient symptoms -- performance status, pain, diarrhea, nausea and vomiting, neuropathy, distress, depression -- at each visit and to utilize a patient-reported outcomes tool; A measure of adherence to clinical practice standards in delivery of all elements of care (in addition to chemotherapy), including but not limited to advanced imaging; Documentation that palliative care is delivered according to patient preference; and Documentation that advanced illness needs have been discussed. We also urge that new systems for oncology care reimbursement incorporate protections to ensure that patients do not experience barriers to innovations in treatment, including new prescription drugs and other services and products. Adherence to practice guidelines may be sufficient to offer these protections, but we urge special attention to access to new therapies that represent treatment advances. Reform of the Cost-Sharing Responsibilities for Cancer Patients The cost of cancer care has been identified as a common cause of medical bankruptcy. Even those who are not pushed to bankruptcy by the cost of their care may find that their costsharing responsibilities influence their decisions about treatment. Patients may choose chemotherapy drugs according to their route of administration, if one has a different and more manageable cost-sharing amount. Patients may also choose not to finish a course of cancer treatment because the financial toxicities of the treatment are simply too great. These choices may mean that patients reject the treatment that is best for them, based on the evidence, and choose instead a more affordable treatment. The overhaul of the payment system presents an opportunity to reconsider the cost-sharing responsibilities for those whose care is reimbursed by a bundled payment or an episode-based payment. Care should be taken to ensure that cost-sharing is reasonable and that it does not unreasonably influence treatment choices. The overhaul of cancer care reimbursement presents an important opening for bringing a more rational approach to patient cost-sharing, and we urge careful attention to this matter. Special care must also be directed to the rules for participation in cancer clinical trials. If a patient who is cared for through a patient-centered oncology medical home and whose care is reimbursed through and episode of care payment enrolls in a cancer clinical trial, there must be clear standards or rules for the cost-sharing that patient will shoulder for the trial. In the

Medicare Advantage system, which bears some similarities to the situation described above, beneficiary enrollment in a clinical trial triggers fee-for-service reimbursement and cost-sharing responsibilities. This practice serves to discourage Medicare Advantage enrollees from participating in clinical trials. Steps must be taken to avoid the same result in a patient-centered oncology medical home/episode or bundled payment system. We appreciate the opportunity to offer these comments on the work of CMS and CMMI and Mitre and the Brookings Institution on payment reform. Sincerely, Cancer Leadership Council CancerCare Cancer Support Community Free to Breathe Hematology/Oncology Pharmacy Association International Myeloma Foundation Kidney Cancer Association The Leukemia & Lymphoma Society LIVESTRONG Foundation Lymphoma Research Foundation Ovarian Cancer National Alliance National Coalition for Cancer Survivorship Prevent Cancer Foundation Susan G. Komen Us TOO International Prostate Cancer Education and Support Network