ASCO submitted comments to the Centers for Medicare & Medicaid Services (CMS) in response to the fiscal year (FY) 2023 Medicare Hospital Inpatient Prospective Payment System (IPPS) and Long-Term Care Hospital (LTCH) Prospective Payment System (PPS) proposed rule. ASCO’s comments address chimeric antigen receptor (CAR) T-cell reimbursement and respond to several Requests for Information (RFI) on social determinants of health data collection, measuring health-care disparities across CMS’s quality programs, climate change, and advancing digital quality.
CAR T-Cell Reimbursement
ASCO expressed continued concerns that the reimbursement rate for the Medicare Severity Diagnosis Related Group (MS-DRG) for CAR T-cell services, MS-DRG 018, is insufficient to cover the cost of CAR T-cell therapies and related services. Current reimbursement rates leave providers with financial losses and could result in restricted access to this life-saving therapy. Under the proposed methodology, if a hospital submits quality data and is a meaningful electronic health record user with a wage index greater than one, the unadjusted payment amount for CAR T-cell services will be approximately $299,460 in FY 2023. This is considerably less than the cost of the drugs alone, which range from $373,000 to $475,000.
Social Determinants of Health Diagnosis Codes
CMS sought information from stakeholders on how the reporting of ICD-10 diagnosis codes in categories Z55-Z65 may improve the agency’s ability to recognize the severity of illness, complexity of illness, and/or use of resources under MS-DRGs. ASCO strongly supports understanding and addressing the social determinants of health (SDOH) for patients with cancer, and the Association made the following recommendations for the collection of such data:
- CMS should define the scope of information collection burden on physicians and other providers who will be required to report SDOH data.
- CMS should work with the provider community on the technical issues hindering streamlining data-collection efforts.
- CMS should work with providers to develop guidance on SDOH data collection as well as strategies to address SDOH issues when appropriate resources are not available in providers’ communities.
Measuring Health-Care Quality Disparities Across CMS Quality Programs
CMS sought information from stakeholders on developing future policies around the use of measure stratification as one quality measurement tool to address health-care disparities and advance health equity across all quality programs. ASCO is pleased that CMS has placed an emphasis on addressing health equity across all quality programs in its continued efforts to move toward a value-based model of care delivery. ASCO urged CMS to establish consistent measures across its various programs to reduce reporting burden and to enhance robustness of the data collected.
ASCO also expressed its intention to collaborate with the administration on exploring policies to mitigate the impact of medical waste and other ways health care contributes to climate change, as well as advancing digital quality measurement and the use of Fast Healthcare Interoperability Resources (FHIR) in quality programs.
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