CLC SUBMITS COMMENTS ON PROPOSED CALENDAR YEAR 2004 UPDATE
OF HOSPITAL OUTPATIENT PROSPECTIVE PAYMENT SYSTEM (HOPPS)
(October 6, 2003)
RE: Hospital Outpatient
Prospective Payment System
Dear Mr. Scully:
Our organizations represent cancer patients, providers and research organizations, and, as such, we write to express our serious concern about reimbursement reductions for radiation oncology treatment in the hospital outpatient setting. The proposed rule on the hospital outpatient prospective payment system (HOPPS), 68 Fed. Reg. 47966, threatens access to quality cancer care by imposing unreasonable and unjustified reductions in payment for life-saving therapeutic radiological services in hospital outpatient departments.
in its various forms is a cornerstone of modern cancer care. More than
half of all patients diagnosed with cancer receive radiation treatment
at some point in their therapy. It is therefore essential that reimbursement
be adequate to warrant the often substantial investment in the sophisticated
equipment and infrastructure necessary for radiation therapy. Significant
unjustified reductions in payment for radiation oncology will not only
place current services at risk, but also discourage investment in new
radiation treatment devices and methods as they become available. Like
any other providers, radiation oncology departments cannot be expected
to operate with losses or even with accumulating unexplained reductions
We are disturbed about both the specific reductions set forth in the proposed rule and the general impact on radiation oncology departments resulting from the cumulative specific reductions. For example, external beam radiation therapy, which is perhaps the most frequently utilized radiation treatment, suffers substantial reductions in payment under the proposed rule. Hospitals confronting reduced payments will be discouraged from maintaining or expanding their services in this critical area, and eventually issues of access to this life-saving treatment will emerge in many locations. A new approach to using external beam radiotherapy, intensity modulated radiotherapy (IMRT) is especially disadvantaged by the proposed reductions. They will create a disincentive for hospitals to invest the necessary capitol to purchase new equipment or upgrade linear accelerators and treatment planning software to provide this service.
Another area of major concern is brachytherapy, which is one of the more important treatment options for certain kinds of cancer. Payment levels appear to be less than adequate to compensate providers for the cost of this extremely important therapy. Again, if providers are unable to recover their real costs involved in specific procedures, particularly those requiring significant out-of-pocket expenses, there will inevitably be irresistible pressures to abandon them.
Radiation oncology is life-saving for people suffering from major cancers like those of the breast, prostate and lung. If Medicare, as the overwhelming primary payer for patients with cancer, significantly under-reimburses for this therapy, the consequences may be dire indeed, not just for Medicare patients but for the nation's entire health care system.
We urge the Centers for Medicare & Medicaid Services (CMS) to reconsider the proposed reductions in payment for these essential services.
American Society of
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