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

Author: Community Oncology Alliance

August 1, 2015

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 arrangements among providers that result in care being provided in higher paid settings, thereby increasing total Medicare spending and beneficiary cost sharing. In general, the Commission maintains that Medicare should base payment rates on the resources needed to treat patients in the most efficient setting, adjusting for differences in patient severity to the extent that severity differences affect costs more for that service in one setting than in another.”

2 Community Oncology Practice Impact Report; Community Oncology Alliance, October 2014.

3 Results of Analyses for Chemotherapy Administration Utilization and Chemotherapy Drug Utilization, 2005-2011 for Medicare Fee-for-Service Beneficiaries, The Moran Company, May 2013.