ASRS Opposes Medicare Part B Drug Demo
The Centers for Medicare & Medicaid Services’ (CMS) proposed rule includes a Medicare Part B Drug Payment Demonstration Project to evaluate alternative payment models. Phase 1 of the demo seeks to determine if physician prescribing patterns will change if the current 'add on' (+6, which is now +4.2% due to sequestration) is replaced by 2.5% (approximately .86 percent with sequestration) plus an additional flat $16.80 administrative fee.
It is important to note that the current add on was congressionally mandated to cover the costs associated with procuring, storing, administering, tracking, and obtaining reimbursement for expensive Part B drugs and does not constitute profit.
The ASRS supports CMS stated goals of “improving incentives for the best clinical care” and desire to “drive the prescribing of the most effective drugs.” The Society also wholeheartedly supports the alternative payment model framework proposed by the Medicare Payment Advisory Commission (MedPAC) Commissioners in December 2014 and agrees that a successful alternative payment system must:
- Provide sufficient incentive for providers to maximize health outcomes and value while reducing costs;
- Ensure that payment policies do not compromise quality of care or limit patients’ treatment options;
- Assess the impact of such payment policies on low-income patients; and
- Implement a sufficiently transparent and adequate exceptions process to allow providers to prescribe more-expensive products when medically necessary.
However, the proposed demo fails to meet the Agency’s stated goal or the standards set forth by MedPAC.
ASRS Independent Cost Analysis
ASRS has conducted an independent analysis of practice costs and has determined that the Part B Demo Project as currently drawn would put many practices – especially small and rural – underwater and threaten access to essential treatment for vulnerable Medicare patients.
ASRS has called for CMS to take time to gather real-world cost data to provide a realistic framework on which to build a truly successful payment model. In the meantime, ASRS continues to expand its analysis to support its data-driven advocacy efforts and recommendations to CMS.
ASRS Submits Comment Letter Opposing Part B Demo Project - May 10, 2016