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Position Statements & Comment Letters


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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January 2017

The Legal and Constitutional Case: Why CMS Did Not Have the Authority to Apply the Sequester Cut to Medicare Part B Drug Reimbursement

For years, the budget of the Obama Administration included a reimbursement payment cut to Medicare Part B drugs, which are generally infusible drugs to treat cancer and other complex, potentially life-threating diseases administered in a clinical setting. However, Congress has fixed Medicare Part B drug reimbursement in statute with the Medicare Modernization Act of

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August 2015

COA submitted comments to CMS on the 2016 Medicare Physician Fee Schedule proposed rule

1 Report to the Congress: Health Care and the Health Care Delivery System, MedPAC, June 2013. MedPAC states in  part, “If the same service can be safely provided in different settings, a prudent purchaser should not pay more for that service in one setting than in another. Payment variations across settings may encourage

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