On August 21, 2017, ONS submitted comments to Centers for Medicare and Medicaid Services Administrator Seema Verma, opposing the agency’s proposed policy to include Medicare Part B drugs in the calculation of Merit-Based Incentive Payment System (MIPS) payment adjustments.
In its comments, ONS noted that small and rural practices already struggle to purchase chemotherapy medications for Medicare patients at the current average sales price (ASP) + 6%—and is even harder at ASP + 4.3% with sequestration. Therefore, subjecting Part B drugs to a potentially negative MIPS adjustment would be detrimental to the provision of chemotherapy for these practices.
ONS also explained that the current ASP payment rate helps cover unreimbursed costs, including oncology nursing services such as delivering cancer therapies and patient education.
How Does the Proposal Affect Oncology Nursing?
Oncology nurses, particularly those working in community-based oncology practices and in rural or underserved areas, should not be impeded from administering and monitoring the medically necessary cancer drugs their patients need. Should the MIPS policy take effect, it could result in permanently closing the doors of small, rural oncology practices. In addition to limiting access to vulnerable Medicare beneficiaries, oncology nurses could potentially lose their jobs at these locations.
In other comments, ONS urged CMS to establish a technical expert panel to look to develop advancing care information measures to capture the important contributions of nurses, particularly in cancer care. ONS expressed the view that the role of nurses should be a criterion for evaluating physician-focused payment models and urged a closer look assessing how nursing contributes to care delivery improvements.