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Read the RheumWATCH archives on topics such as rheumatology advocacy, policy updates, insurance advocacy, and practice management.
Last week, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule outlining an initiative that would lower the reimbursement rate for Medicare Part B drugs. The ACR is reviewing the proposal, and is deeply concerned that it could include a reimbursement cut that would make it economically unfeasible for rheumatologists to continue providing in-office biologic infusions to Medicare patients.
The ACR recently joined more than 100 groups across various provider and patient advocacy communities in signing on to a stakeholder letter urging CMS to reconsider its proposal. Today the ACR has joined more than 300 provider and patient groups in a letter asking leaders in Congress to request that the proposal be withdrawn.
Comments from the ACR President
“Many rheumatologists have already been forced to stop providing in-office treatments because the current Medicare reimbursement rate does not cover the cost of administering these highly complex therapies. It is our hope that future payment changes would not exacerbate the existing access problem and force more patients to receive biologic therapies in the hospital setting, where they will be faced with higher copayments, more expensive facility fees, and potentially longer travel times. Worse yet, we do not want to see patients forced to receive home infusions of complex therapies without proper supervision,” said Joan Von Feldt, MD, MSEd, President of the ACR.
“The ACR is currently reviewing the CMS proposed rule to assess the full impact it will have on our Medicare patients’ ability to access life-saving and medically necessary care. We look forward to continued dialogue with CMS about the unique care needs of rheumatology patients and the complexities in their care that influence our prescribing decisions. The ACR will submit detailed comments to CMS in the coming weeks in response to the proposed rule.”
Keep checking the RheumWATCH page for more information in the coming weeks.
The ACR, in partnership with the American Association of Hip and Knee Surgeons (AAHKS), is developing a new clinical practice guideline for perioperative management of rheumatic disease medications in total joint arthroplasty of the hip and knee. The guideline will be developed primarily for orthopedic surgeons and rheumatologists who care for patients undergoing total joint arthroplasty, but may also be used by other providers who care for these patients.
The ACR strongly encourages its members and others to comment on the project plan that will be used in this guideline development by March 24, 2016.
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The mission of the ACR cannot be achieved without the time, effort, talent, and experience of its volunteer leadership and committee members. The College welcomes self-nominations or nominations of colleagues for open volunteer positions, including committee appointments.
Committee appointments are made each year in conjunction with the ACR/ARHP Annual Meeting. Most elected terms are for three years, beginning at the Annual Meeting. The nominations deadline for ACR and Rheumatology Research Foundation volunteers is June 1, and accepted candidates will be notified at the end of the summer.
New this year: Microvolunteering opportunities are available! Microvolunteering is perfect for those who want to contribute to the ACR through short-term, low time commitment opportunities. Applications are accepted year round.
Last week, CMS released its proposed rule to change payment for Part B drugs. The rule is described as a variety of test methodologies to address some of the actual or perceived incentives to prescribe higher-cost drugs or to add incentives to use lower-cost ones. The rule has been widely covered in the press, and CMS is already hitting the press circuit themselves. The rule itself is 119 pages long and is undergoing a full review by the ACR. The comment period ends May 9. Let me tell you a little about how the process works and the response the ACR is planning.
First, a word about how the comment period mechanically works: CMS will gather all the comments over the following weeks, but they won't look at the letters until May 9. Basically, as far as CMS goes, there is no prize for getting our angry comment letter submitted tomorrow. Rather, our best chance at a prize is a thoughtful point-by-point refutation of the proposal. This includes dissection and challenge of the flawed premise that underlies some of the proposals. We can only do that by methodically addressing each section in those 119 pages.
As we do that, we have to understand CMS’s motivation (the detailed one, not the obvious “follow the money” nonsense) and take it apart piece by piece. Also, we need to focus on rheumatology specifically, and help CMS understand that broad pronouncements and assumptions don't apply universally. For example, it is factually true that, all other things being equal, Average Sales Price + (6 - 2 = 4) would generate higher reimbursement if the drug cost more. But all other things are most definitely not equal. In particular, in rheumatology, there isn’t a whole host of Part B options from which we can choose the cheapest. This is only one of many, many arguments to make.
The ACR is already taking preliminary steps to address this issue. First, a group consisting of key committee chairs, including Government Affairs, Rheumatologic Care, and the Insurance Subcommittee, and several board members has been assembled and is ready to start addressing any new salvos that come our way. That group had a call last week only hours after the release. The obvious result is that the ACR will respond to the proposed rule. In addition, we will be pulling in other experts and members to help formulate our response. We will consider the value and timing of engaging patients. The value is obvious, the timing less so.
We also will have meetings in the coming months with key legislators and perhaps some regulators to get help applying pressure to CMS. In order to help us best sort out our options and rebuttals, we are also working with regulatory advisors with expertise from previous dealings with CMS and other regulators. The ACR response will be comprehensive, reasoned, and forceful. That will be our best opportunity for changing the proposal, and it will take the entire two-month period to get it right.
You will hear more about this topic, and when we have completed summaries of the rule, we will provide access to them. We will continue communicating with our members about what we are doing on your behalf. We will ask for your help at particularly strategic times to write editorials and letters to Congress, and to recruit patients to join. This will take all of us, and I know we'll band together over this latest headache. I look forward to talking to you again soon.
Will Harvey, MD, MSc