Debra Madden is a 2-time cancer survivor who was diagnosed with Hodgkin's lymphoma as a young adult and breast cancer nearly 20 years later, which was thought to be secondary to the radiation she had received for her original cancer treatment. Debra became an active Cancer Research Advocate following her second cancer diagnosis at the age of 42 years. She is currently a member of the ECOG/ACRIN Cancer Research Group and the Patient-Centered Outcomes Research Institute's Advisory Panel on the Assessment of Prevention, Diagnosis, and Treatment Options. She also serves on multiple grant review panels, including the Congressionally Directed Medical Research Program Breast Cancer Research Program. Debra blogs at "Musings of a Cancer Research Advocate", (https://draemadden.wordpress.com/) and you can follow her on Twitter at @AdvocateDebM.
Why this patient advocate is concerned about the newly proposed Medicare Part B model regarding its level of transparency and the evidence.
“Facts are stubborn things; and whatever may be our wishes, our inclinations, or the dictates of our passion, they cannot alter the state of facts and evidence.” ~John Adams, from The Portable John Adams
As a young adult cancer survivor, an active cancer research advocate, and an American citizen, I’ve become increasingly concerned as I watch our country slide deeper into contentious, complex, and combative debates about healthcare access, coverage, and cost. When CMS recently announced a plan to test new payment models for Medicare Part B prescription drugs in an attempt to lower costs, this served to further fan the flames for many, including myself, where my alarm grew on 2 important fronts:
Both areas have generated a tremendous amount of controversy—with many clinician organizations, hospitals, and patient advocacy groups expressing adamant opposition to the CMS initiative overall. I share this deep concern regarding the first part of the proposal. Today, when Part B drugs are administered for patients, CMS typically pays providers the Average Sales Price (“ASP”) plus a 6% add-on. But with this proposed demonstration project, CMS will geographically randomize clinicians, testing whether decreasing the add-on payment to 2.5% plus a flat fee of $16.80 per drug per day impacts prescribing incentives and clinicians’ prescribing patterns. In contrast, as noted above, my concern regarding the value-based portion of the proposal is the reaction to that proposal. Although this may seem contradictory, the basis of my concern is actually the same: the level of transparency and evidence that underlie both.
An Experiment to Reduce Costs
Let me begin with the proposed change to the ASP payments to those providers who are treating patients with prescription Part B medications in the clinic, including infused oncology drugs. My misgivings are many, including that:
Further, this portion of the proposal does not appear to be based on any evidence. Rather, CMS is making a troubling assumption that oncologists and other clinicians are basing drug treatment decisions solely on financial incentives—rather than selecting the optimal treatment for each individual patient based on the clinical evidence. Many cancer groups that are opposed to the proposal appropriately argue that no data exist to support CMS’ assumption that changing their payment schema would reduce costs or enhance care. In its March 8, 2016, edition, The Cancer Letter notes the results from a voluntary UnitedHealthcare project with 5 community oncology practices, where removing financial chemotherapy drug incentives actually proved the opposite to CMS’ assumption. When compared with a national fee-for-service payer registry, when the cost difference was analyzed before and after introduction of the payment change, eliminating the chemotherapy drug incentives actually increased the use of chemotherapy. Further, the predicted fee-for-service cost of the cohort based on the registry was projected to be $98.1 million, whereas the total cost was almost a third lower at $64.8 million.
As the paper concluded, “Modifying the current fee-for-service payment system for cancer therapy with feedback data and financial incentives that reward outcomes and cost efficiency resulted in a significant total cost reduction.” (The emphasis is mine.) Importantly, such savings were generated without impacting quality and without any measureable impact on toxicity.
Despite the fact that the CMS project references “value-based pricing” in the second part of the proposal, the crux of the problem with the ASP portion is that CMS does not appear to include value and quality of care as endpoints, did not engage critical stakeholders in the development of the proposal, and is focusing solely on drug utilization and associated costs.
In Part II of this article, Ms Madden will discuss her concerns from her perspective as a patient advocate regarding the reactions of many stakeholders to the value-based pricing proposed in the CMS Part B Drug Payment Model.