Access to Integrated Cancer Care
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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

  • 97 percent of the responding physician practices expect that they would have to reduce the hours of or layoff non-physician staff if CMS's proposed policies are finalized.

  • 34 percent of the physician practices surveyed expect that they would have to reduce the number of physicians providing integrated cancer care and other health care services to their patients.

  • Although in many cases radiation therapy services would be available within 25 miles to patients who were no longer able to receive the services from a surveyed multi-specialty physician group practice, 20 percent of the responding practices indicated that the equipment and technology at the other available facilities is inferior to what is available in the physician's medical practice.

  • 88 percent of the responding practices would delay scheduled equipment upgrades, resulting in reduced access to cutting edge technology often not found in the facility setting.

  • 91 percent of the responding practices anticipate having to reduce the amount of indigent care that they furnish, as well as reduce community outreach and charitable efforts.

  • Five physician practices stated that they may have to discontinue their medical practice operations altogether, jeopardizing cancer care to over 10,000 patients in five states.


Click here to read AICC's Comments on CMS-1413-P

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