AICC'S RESPONSE TO CMS
On August 28, 2009, Access to Integrated Cancer Care (AICC) submitted to the Center for Medicare & Medicaid Services (CMS) detailed comments on the Proposed Medicare Payment Policies under the Physician Fee Schedule and other Revisions to Part B for Calendar Year 2010. Specifically, AICC's comments addressed CMS's proposed changes with respect to (i) the equipment utilization rate assumption applicable to all equipment with a purchase price over $1 million; (ii) the elimination of the malpractice expense component for radiation oncology; and (iii) the proposed policy with respect to physicians' services and the sustainable growth rate system Medicare Physician Fee Schedule -21.5 percent update.
In addition to identifying a series of legal infirmities with CMS's proposals, AICC presented data collected from a nationwide survey it conducted of 875 physicians who provide patients with comprehensive cancer care within multi-specialty physician practices. AICC described in its comments how CMS's proposed policies as applied to radiation therapy services, if finalized, would result in reimbursement cuts that would be devastating for the delivery of integrated cancer care in the multi-specialty physician practice setting. By way of example, AICC noted that
Click here to read AICC's Comments on CMS-1413-P