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Position Statements & Comment Letters


January 2019

COA comment letter on CMS plans to “modernize” the Part D program and Medicare Advantage (MA) plans

Submitted electronically to: http://www.regulations.gov The Honorable Seema Verma, Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-4180-P P.O. Box 8013 Baltimore, MD 21244-8013 Re: Modernizing Part D and Medicare Advantage to Lower Drug Prices and Reduce Out of Pocket Expenses; CMS-4180-P Dear Administrator Verma: On behalf of the Board

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December 2018

COA Comments on IPI for Medicare Part B Drugs

The Honorable Seema Verma, Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-5528-ANPRM P.O. Box 8016 Baltimore, MD 21244-8013 Re: Medicare Program; International Pricing Index Model for Medicare Part B Drugs; CMS-5528- ANPRM Dear Administrator Verma: On behalf of the Board of Directors of the Community Oncology Alliance (COA),

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December 2018

COA Comments Objecting to CVS-Aetna Merger

Peter Mucchetti, Esq. Peter.J.Mucchetti@usdoj.gov Antitrust.atr@usdoj.gov Chief, Healthcare and Consumer Products Section, Antitrust Division, Department of Justice 450 Fifth Street NW, Suite 4100 Washington, DC 20530 RE: United States of America v. CVS Health Corporation and Aetna Inc. Dkt. No.: 1:18-cv-02340 Dear Mr. Mucchetti: The Community Oncology Alliance (“COA”) submits this letter on behalf of

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November 2018

COA Comments on Revisions to USP General Chapter 797 Pharmaceutical Compounding – Sterile Preparations

Submitted electronically to: CompoundingSL@usp.org Ronald T. Piervincenzi, Ph.D. Chief Executive Officer U.S. Pharmacopeial Convention 12601 Twinbrook Parkway Rockville, MD 20852-1790 Re: Comments to Proposed Revisions to USP General Chapter <797> Pharmaceutical Compounding – Sterile Preparations Dear Dr. Piervincenzi, On behalf of the Board of Directors of the Community Oncology Alliance (COA), we thank you

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September 2018

COA Formal Comments on 2019 HOPPS Proposed

Submitted electronically to: http://www.regulations.gov The Honorable Seema Verma, Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-1695-P P.O. Box 8016 Baltimore, MD 21244-8013 Re: Medicare Program: Proposed Changes to Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs; Requests for Information on Promoting

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September 2018

COA Comments on 2019 Medicare Physician Fee Schedule

Submitted electronically to: http://www.regulations.gov The Honorable Seema Verma, Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-1693-P P.O. Box 8016 Baltimore, MD 21244-8013 Re: Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY2019; Medicare Shared Savings Program Requirements;

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July 2018

Community Oncology Alliance Submits Formal Comments on President’s Blueprint to Reduce Drug Prices

RE: Request for Information on U.S. Department of Health and Human Services (HHS) Blueprint to Lower Drug Prices and Reduce Out-of-Pocket Costs (CMS-2018-0075-0001) On behalf of the Board of Directors of the Community Oncology Alliance (COA), I am submitting this comment letter in response to the U.S. Department of Health and Human Services (HHS)

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March 2018

Letter to CMMI Detailing OCM Concerns

Anand Shah, MD Chief Medical Officer, Center for Medicare & Medicaid Innovation Centers for Medicare & Medicaid Services 7500 Security Boulevard Baltimore, MD 21244 Dear Dr. Shah: On behalf of the Community Oncology Alliance (COA), we are submitting our concerns regarding the Oncology Care Model (OCM) to the leadership at the Center for Medicare

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January 2018

COA Submits Formal Comments on Medicare Advantage and the Prescription Drug Benefit Program

1 Executive Summary 2016 was a year of intense focus, debate, and even epiphany as to the reasoning behind our nation’s escalating drug costs and their impact on both the Medicare program and beneficiaries. The media, public, and legislators began to recognize that pharmacy benefit managers (“PBMs”)—once seen as the key to controlling

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October 2017

Improving Patient Outcomes and Coordination of Care: Importance of Oncology Dispensing in the State of New York

1    Executive Summary Physician dispensing has been a critical part of the American healthcare system for decades, and dispensing physician practices have participated as in-network providers for various Medicare Part D pharmacy networks since the implementation of the Medicare Part D program in 2006. There is good reason for this. Receiving medication directly from

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