COA Formal Comments on International Pricing Index Model for Medicare Part B Drugs

Author: Community Oncology Alliance

December 31, 2018

On behalf of the Board of Directors of the Community Oncology Alliance (COA), we are submitting this comment letter regarding the Medicare Program; International Pricing Index Model for Medicare Part B Drugs (CMS-5528-ANPRM) (the “IPI Model”).

As you know, COA is an organization that is dedicated to advocating for the complex care and access needs of cancer patients and the community oncology practices that serve them. COA is the only non-profit organization in the United States dedicated solely to independent community oncology practices, which serve the majority of Americans receiving treatment for cancer. COA’s mission is to ensure that cancer patients receive quality, affordable, and accessible cancer care in their own communities where they live and work. For more than 15 years, COA has built a national grassroots network of community oncology practices to advocate for public policies to support cancer patients.

First, we want to say that we appreciate your openness and interest in understanding our position on this important topic of the cost of prescription drugs in the Medicare Part B program (“Part B”), as well as the overall total cost of cancer care, which is comprised of drugs and services, both hospital and physician related. We thank you for meeting with us on two occasions leading up to the preparation and submission of this comment letter, as well as the opportunity to submit this letter. Although we are very concerned about escalating drug prices/costs and the high total cost of cancer care, as we have expressed to you, COA does not support the IPI Model as proposed in the pre- proposed rule published by the Centers for Medicare & Medicaid Services (“CMS”) because we have serious concerns about its impact on cancer patient care and even its legality. That said, we are actively working on solutions to high drug costs and the total cost of cancer care and, as we outline in this comment letter, are developing and analyzing alternatives to the model.

COA is sincerely committed to oncology payment reform that makes cancer care more affordable, as witnessed by our commitment and involvement in the Oncology Care Model (“OCM”); our ongoing development of the OCM 2.0, a next-generation, more universal oncology payment model; the numerous summits and meetings we have held with payers, employers, stakeholders, and providers; and the involvement of community practices, like ours, in an incredible number of private insurance payment models and programs. Community oncologists are concerned about the escalating prices and costs of cancer drugs, as well as high hospital-related costs, all of which contribute to the overall increasing total cost of cancer care. As leaders in the delivery of cancer care, we are mindful of our responsibility to be good stewards of costs we can control, including the utilization of drugs and services.

In this letter, we will detail our problems and concerns regarding the IPI Model as proposed, even though we have summarized these with you, leadership, and staff from CMS and the CMS Innovation Center (“CMMI”) in previous exchanges. We understand and appreciate that CMS appears to be already considering changes to its proposed model, and implementation of it, based on input from COA and providers. However, we believe it is important to detail our concerns with the IPI Model as proposed, for both the sake of memorializing our comments and as understanding the basis for our alternative suggestions.

In this comment letter, we will also outline alternatives to the IPI Model, which we are currently working on in greater detail. Some of that detail will not be available in this comment letter, given the submission deadline of 12/31 and the holiday season, coupled with the fact that we have much more analytical work to do on these alternatives.

We hope to continue the dialogue with CMS post submission of this comment letter, as we continue our analytical process and CMS moves towards a proposed rule on the IPI Model.