Today the Community Oncology Alliance (COA) released the following statement regarding the Advanced Notice of Proposed Rulemaking (ANPRM) for an International Pricing Index (IPI) Model unveiled by President Trump and United States Secretary of Health and Human Services (HHS) Alex Azar II:
First and foremost, COA is very concerned about ensuring that Medicare seniors have timely and unrestricted access to the most effective and potentially life-saving, physician-prescribed cancer treatments, and without interference from corporate middlemen. This is particularly true given that cancer treatment is becoming more precise and individualized, yet corporate middlemen in Medicare Part D and with private insurance pharmacy benefit plans are increasingly blocking patients from getting their cancer treatments on a timely basis, with the correct dosage, if at all.
COA cautions the administration against disruptive changes to the current Part B drug distribution and cancer care delivery system, which is time-proven as effective and efficient for patients with patients. COA is concerned that the IPI will either repeat past reform mistakes (such as the Competitive Acquisition Program, CAP) or introduce the same cancer treatment access challenges experienced by cancer patients today with pharmacy benefit managers (PBMs) and other middlemen under Medicare Part D.
COA believes that any proposals to introduce new third-party middlemen to the Part B system, as the IPI possibly proposes with new “private sector vendors” (translation: middlemen), will interfere with the quality, accuracy, and timeliness of treatment for Medicare beneficiaries.
As it stands today, physicians report that PBM middlemen in Part D reduce care choices, drive up costs, increase administrative burdens, and interfere with physician-patient decision making. Indeed, while proposals for middlemen often focus only on the economic impact of new middlemen vendors, there is scant discussion about the impact they currently have on patients. COA has documented real-life patient horror stories from practices and physicians about patients battling cancer who have suffered at the hands of PBMs due to delayed coverage decisions, denial of coverage, arguments with physicians over proper treatment, and failure to receive medications in a timely manner.
“What the administration is proposing is incredibly complex and extremely difficult to comprehend how it would be implemented in the real-world of medical practice. Their premise that oncologists use drugs based on financial incentives is simply not founded in fact and calls into question the need for this convoluted upheaval of the current cancer care delivery system,” said Ted Okon, executive director of COA. “It is also disturbing that the administration is trying to end-run the Congress by forcing a mandatory CMS Innovation Center demonstration that will effectively change Medicare reimbursement, as the sequester cut to Part B drug reimbursement has already done.”
The notion that physicians, and oncologists in particular, practice medicine driven by financial incentives is not only false, but also highly offensive. Every decision made, and every drug prescribed, is for the good of patients and the patient-specific clinical situation, often driven by well-established, evidence-based clinical guidelines. Numerous independent studies have shown that the ‘incentive’ of reimbursement rates does not change oncologists’ prescribing patterns. Rather, it is the introduction of new, groundbreaking drugs and clinical evidence that dictates which treatment is best for the patient. Not only is there no current and accurate data supporting that assumption but studies, including one published just last month that states exactly the opposite.
“As a practicing oncologist, I see the impact of high drug costs firsthand every day and agree that we must do something to address them. However, this preliminary proposal seems to have no consideration of how it might adversely affect cancer care for Medicare seniors – or even be practically implemented,” said Jeffrey Vacirca, MD, FACP. board-certified hematologist and oncologist at New York Cancer & Blood Specialists, where he serves as CEO and managing partner. He is also the current president of the Community Oncology Alliance.. “And frankly, the notion of financial incentives directing how I provide cancer care to my patients is absurd. Using me and my oncologist colleagues in an attempt to bring down drug prices is bad policy and terrible medicine.”
As the frontline providers of care for the majority of Americans battling cancer, independent community oncologists are highly aware that the trend of continuously increasing drug prices and cancer care costs is unsustainable and unacceptable. COA and community oncology practices are actively working on solutions to high drug prices and the cost of cancer care by relying on the real-world medical expertise of providers on the front lines of cancer care to craft viable, truly patient-centric solutions. This includes providing practices with the support that they need to succeed in the Centers for Medicare & Medicaid Innovation Oncology Care Model (OCM), as well as by developing the OCM 2.0, a universal model of oncology payment reform that includes value-based payments for drugs and services.
COA will be providing comments on the ANPRM and IPI payment model, as requested by HHS. However, we must strongly warn policymakers that even well-intended policymaking can backfire and result in the unintended consequences of harming patients, increasing costs, and limiting access to care. This has been particularly true in cancer care, where Americans today are facing the financial impact of previous policymaking such as the sequester cut to Medicare drug reimbursement, growing negative presence of PBMs, and the out of control 340B drug pricing program in hospitals. These were all introduced to reduce health care costs but have, ironically, resulted in increased spending and bureaucracy that is adverse to patients, especially those with cancer.