The following is a press release from the ACR from this last Thursday:

In comments submitted to the Centers for Medicare and Medicaid Services (CMS), the American College of Rheumatology (ACR) urged the agency to proceed with caution when considering the International Pricing Index (IPI) drug pricing model, which was announced in an Advance Notice of Proposed Rulemaking in October. The ACR is concerned that, without substantial changes, the demonstration program could disrupt patient access to care, worsen the rheumatology workforce shortage and exacerbate geographic disparities in access to medical care.

“We appreciate the opportunity to provide input on the proposed IPI model and are encouraged by the agency’s efforts to make needed therapies more affordable for patients,” said Paula Marchetta, MD, MBA, president of the American College of Rheumatology. “However, we believe that changes must be made to ensure the proposal does not result in significant disruptions in patient care for the 54 million Americans who live with a rheumatic disease.”

Specifically, the ACR recommends that the IPI demonstration:

• Be voluntary. Participation in this demonstration must be voluntary for providers and must include a way for them to exit the program if they find themselves unable to meet the administrative and financial changes required. Furthermore, the proposed demonstration should be reduced in size and scope and encompass a significantly smaller percentage of Part B drug administration to avoid disruptions in patient care.
• Reduce financial risks and administrative burdens to physicians. In order to avoid disruptions in patient access to treatments, ACR opposes any increased risk to patients and practices as a result of the demonstration. The ACR is concerned that the proposal to have providers collect patient cost-sharing payments would create serious financial risk and administrative burdens for physicians, particularly those operating small practices. Instead, the ACR recommends that if third-party vendors are tasked with drug procurement and distribution under the proposed model, that they also collect the payments themselves or pay providers a fee for the cost collection. Other administrative changes were suggested in the ACR’s comments.
• Measure the impact on patient access to inform future developments. CMS should continuously track and report measures such as prescription adherence, out-of-pocket costs, and disease outcomes throughout the demonstration to ensure the model does not compromise patient access or health outcomes in favor of lower costs.

Over the summer, the ACR released a set of policy principles that must be at the forefront of any policy effort aimed at reducing drug costs for chronically ill Medicare patients. These principles include prioritizing patient access to affordable treatments while ensuring steps are taken to support shared decision-making between patients and providers.

“The ACR is dedicated to ensuring that rheumatologists and rheumatology care professionals have the resources they need to provide patients with appropriate, high-quality care,” Dr. Marchetta concluded. “We thank CMS for providing an opportunity to offer our input and we look forward to serving as a resource for the agency as it works to lower drug costs for Americans with chronic illnesses.”

To view the comment letter, click here.

The following is a press release sent today from the American College of Rheumatology.

In comments submitted to the Centers for Medicare and Medicaid Services (CMS) regarding the 2019 Medicare Physician Fee Schedule proposed rule, the American College of Rheumatology (ACR) cautioned policymakers against implementing a proposal to reduce physician reimbursement for evaluation and management (E/M) services, arguing that doing so could severely compromise patient access to care and further exacerbate the growing rheumatology workforce shortage.

“While we applaud CMS for taking steps to reduce provider documentation and reporting burdens, we have serious concerns about the impact these cuts will have on patient access to rheumatology care,” said David Daikh, MD, PhD, President of the ACR. “A one-size-fits-all approach to reimbursement is not the way to move forward, and cuts of this magnitude will not only force physicians to spend less time with patients but could also dissuade medical students from pursuing careers in rheumatology and other specialties that treat a high volume of patients with complex needs.”

CMS’ proposal, which would create a flat payment for all E/M visits regardless of complexity, would result in significant payment cuts for treating patients with complex care needs – penalizing doctors who treat sicker patients or patients with multiple chronic conditions. These cuts also go against the recommendations of the Medicare Payment Advisory Commission (MedPAC), which earlier this year found that E/M services are undervalued relative to other physician services and recommended that reimbursements be increased rather than cut. The ACR recommends that CMS implement only the documentation relief elements of the E/M proposal, while delaying the payment changes so CMS can work closely with physicians and all stakeholders to identify alternative approaches that would ensure physicians are appropriately reimbursed according to the level of care required by each individual patient’s condition.

The ACR also expressed concern that CMS’ proposal to reduce reimbursements for procedures performed on the same day and billed as a separately identifiable E/M visit could reduce quality of care and lead to higher co-pays for patients by requiring them to return on a different day for minor procedures.

Additionally, the ACR urged CMS to:

• Maintain the Merit-Based Incentive Payment System (MIPS) small practice bonus at 5 percent of the final score rather than move it to the quality performance category as is currently proposed.
• Not move forward with a proposal to increase the weight of the cost performance category to 15 percent in the 2021 MIPS payment year. The ACR also urged CMS to use the best 90 days in the Cost category when calculating MIPS payment bonuses rather than the entire calendar year and exclude Part B medication costs from the cost performance category.
• Provide physicians with more credit for participating in specialty clinical data registries under MIPS, such as the ACR RISE Registry which uses electronic health records to improve patient care, outcomes, and practice efficiency.
• Rely on input from all stakeholders about inappropriate and excessive reduction in practice expense reimbursement for diagnostic ultrasound and other services.

“The ACR remains dedicated to ensuring that rheumatologists and rheumatology health professionals have the resources they need to provide patients with high quality care and will continue to advocate for payment reforms that reflect the way practices treat patients,” Dr. Daikh said. “We look forward to serving as a resource for CMS as it develops and implements its final 2019 Physician Fee Schedule rule.”

To view the comment letter, click here.