1. Home
  2. /
  3. Position Statements & Comment...

Position Statements & Comment Letters


April 2019

COA Comments on Proposal to Remove the Safe Harbor Protection From the Federal Anti-Kickback Statute

Submitted electronically to: http://www.regulations.gov The Honorable Alex M. Azar II Secretary United States Department of Health and Human Services Attention: OIG-0936-P 200 Independence Avenue, SW Room 600E Washington, DC 20201 Re: Fraud and Abuse; Removal of Safe Harbor Protection for Rebates Involving Prescription Pharmaceuticals and Creation of New Safe Harbor Protection for Certain Point-of-Sale

Download (PDF) Read Full
April 2019

COA Biosimilars Position Statement

Summary: The Community Oncology Alliance (COA) is committed to advancing knowledge and acceptance of biosimilars as an important, promising element in reducing drug costs and overall health care spending, and the financial toxicity of cancer care for patients. COA will work to support biosimilars and innovative biosimilar (biologic) development with all stakeholders, including policymakers,

Download (PDF) Read Full
March 2019

Proposed Decision Memo for Chimeric Antigen Receptor (CAR) T-cell Therapy for Cancers

The Honorable Seema Verma, Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CAG-00451N P.O. Box 8013 Baltimore, MD 21244-801 Re: Proposed Decision Memo for Chimeric Antigen Receptor (CAR) T-cell Therapy for Cancers; CAG-00451N Dear Administrator Verma: On behalf of the Board of Directors of the Community Oncology Alliance (COA),

Download (PDF) Read Full
February 2019

COA Letter on the Patient Affordability, Value and Efficiency (PAVE) Act

Senator Bill Cassidy 520 Hart Senate Office Building Washington, DC 20510 Senator Mark Warner 703 Hart Senate Office Building Washington, DC 20510 Re: The Patient Affordability, Value and Efficiency Act Dear Senators Cassidy and Warner: On behalf of the Board of Directors of the Community Oncology Alliance (COA), we thank you for the opportunity to

Download (PDF) Read Full
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

Download (PDF) Read Full
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),

Download (PDF) Read Full
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

Download (PDF) Read Full
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

Download (PDF) Read Full
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

Download (PDF) Read Full
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;

Download (PDF) Read Full