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Rose: CMS’ Proposed Cuts Threaten Patients

In today’s fiscal environment, health care providers are accustomed to reimbursement cuts to a great many services. We don’t like them, but we’ve come to expect them, and we’ve all learned to do more with less. When policymakers are tasked with encouraging better outcomes and greater efficiency in the system, we expect decision-makers in Washington, D.C., to take well-informed actions based on quality data and in a manner that puts patients first.

It doesn’t always happen that way.

To the collective shock of cancer care providers nationwide, the Centers for Medicare and Medicaid Services recently proposed a cut of 15 percent to freestanding radiation therapy providers. In fact, two codes critical to the provision of radiation therapy were slashed by as much as 40 percent.

This means $300 million less for the treatment of cancer care. For patients, it will mean less access to treatment when cancer centers close and inability to treat with radiation some of the most common forms of cancer.

How could this happen? The CMS decided to base reimbursement on data that are questionable at best. Instead of relying on validated, auditable survey data, the CMS drew on “patient fact sheets” – educational documentation not intended to inform complex reimbursement policy but rather designed to provide a general education to patients.

This type of incomplete decision-making is at the heart of much of the payment uncertainty that radiation oncology faces. Blending of practice expense data between freestanding and hospital-based centers and inaccuracies with the Physician Practice Information Survey data are but two more methodological issues that lead to bad assumptions, payment uncertainty and an inefficient system of reimbursement.

Over the past three decades, the survival rate for many cancer patients has increased steadily, thanks to advances in and availability of groundbreaking treatments. In the mid-1970s, the five-year survival rate for breast cancer was 75 percent; for prostate cancer it was 69 percent. Today, the five-year survival rate is 90 percent for breast cancer and 99 percent for prostate cancer.

The effects of the CMS’ proposed cuts will be far-reaching. Physicians are worried about having to close their doors, lay off staff, delay updating their equipment and turn away Medicare patients. These proposed cuts would tilt reimbursement policy in favor of being treated in hospitals, where payments would be higher than in a freestanding, community-based setting.

There’s a better way for the CMS to improve the economic sustainability of cancer care. A coalition of more than 200 freestanding radiation therapy centers has been in discussions with the CMS for two years in the hopes of establishing a reformed payment system that ensures patients receive high-quality care, creates predictability for physicians and offers the potential for cost savings.

Moving toward a bundled “episode of care” payment for radiation therapy could reduce the risk inherent in relying on policymakers in Washington to set reimbursement rates while also ensuring more data is available to determine the best care for patients in the future.

Congress and the administration have expressed an interest in bundled payments for cancer care, as evidenced by a study on the subject mandated in the most recent “doc fix” legislation.

Americans rely on cancer care providers for lifesaving care. Providers rely on policymakers to advance policies to make this care possible. The CMS’ proposed rule misses the mark with potentially devastating consequences. We hope the CMS will reconsider this decision before the proposed regulation is finalized and will instead embark on an open, comprehensive and fact-based process for ensuring that payments are fair and the quality of cancer care is the highest possible.

Because the CMS comment period for this policy ended Sept. 4, it is urgent that lawmakers understand the gravity of the situation American cancer patients face and put a stop to these cuts.

Christopher M. Rose is a practicing radiation oncologist, co-founder of Vantage Oncology and chairman of the Radiation Therapy Alliance Policy Committee.

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