COA Submits Formal Comments on Medicare International Pricing Proposal

January 2, 2019

Opposes IPI as Proposed Because of Serious Concerns About Patient Impact and Legality but Working on Alternatives

Releases Research Analysis on Myth of Physician Incentives in Part B System

The Community Oncology Alliance (COA) recently submitted formal comments to the Centers for Medicare and Medicaid Services (CMS) regarding the Medicare Program International Pricing Index Model for Medicare Part B Drugs pre-proposed rule, also known as the IPI Model. The letter explains that although community oncology is very concerned about escalating drug costs and the high costs of cancer care, it does not support a mandatory, national experiment on patient care as proposed in the IPI Model. COA has serious concerns about its impact of the IPI Model on the care received by patients with cancer, the impracticality of its design, and its legality, and therefore strongly urges CMS not to move forward with it.

COA’s letter to CMS details problems and concerns with the mandatory, national, and radical IPI Model as proposed alongside a number of solutions to high drug costs and the total cost of cancer care that COA is developing as alternatives to the model. COA hopes to be able to continue working with CMS on constructing a patient-centric, value-driven, voluntary demonstration project with appropriate patient safeguards. Such projects would be enthusiastically supported and COA would help drive large-scale participation by community oncology practices across the country. 

“The IPI Model as proposed is an experiment on cancer patients in the context of a mandatory, national model that COA is against for a host of reasons elaborated on in our comment letter to CMS,” said Ted Okon, executive director of COA. “However, we appreciate the openness of CMS Administrator Verma and other leadership within HHS and CMS to listen to our concerns and suggestions on alternatives to addressing the increasing cost of Part B drugs and services. COA’s numerous initiatives prove its commitment to oncology payment reform and to working closely with this administration, Congress, manufacturers, patient advocates, and other providers on viable, constructive, and effective solutions.”

Seeking solutions, COA has been leading practices in oncology payment reform that makes cancer care more affordable, including a deep commitment and involvement in the Oncology Care Model (OCM); the ongoing development of the OCM 2.0, a next-generation, more universal oncology payment model; numerous summits and meetings with payers, employers, stakeholders, and providers; and the involvement of community practices in an incredible number of private insurance payment models and programs. 

As part of the letter, COA also released a research analysis examining the myth of physician incentives in the Medicare Part B drug reimbursement system. It thoroughly debunks the false narrative that oncologists’ decision-making is driven by financial factors, much of which is based on extremely outdated and/or fundamentally flawed research. In fact, a number of studies on physician prescribing under the Part B reimbursement system have been published in recent years, all of which reach dramatically differing conclusions on physician prescribing patterns.

“There is a flawed, often repeated notion that we oncologists choose treatments based on financial considerations, rather than clinical ones. This is both false and incredibly offensive to us as the front-line providers of cancer care,” said Michael Diaz, MD, president of COA and practicing medical oncologist at Florida Cancer Specialists. “Independent, peer-reviewed research has found that modifying payment for cancer care does not impact clinical decision making for providers, but rather that the factors that actually impact prescribing patterns are the introduction of new drugs, new clinical evidence, and identifying new best-practices for treatment. We choose the best, most appropriate cancer treatment for our patients in close consultation with them.” 

Read COA’s full IPI comment letter to CMS at Read the COA research analysis on Part B prescribing at