(December 23, 2004)


December 23, 2004

Submitted by Mail

Centers for Medicare & Medicaid Services
Department of Health & Human Services
P.O. Box 8012
Baltimore, MD 21244-8012
Attention: CMS-1429-FC

Re: Revisions to Payment Policies Under the Physician Fee Schedule for Calendar Year 2005 [CMS-1429-FC]

To Whom It May Concern:

As organizations involved in cancer treatment, research and patient advocacy, we commend the Centers for Medicare & Medicaid Services (CMS), and you personally, for the recent announcement of a one-year demonstration project to assess quality care for Medicare patients undergoing chemotherapy. This project provides important near-term support for necessary provider services associated with delivery of cancer chemotherapy, but also establishes a foundation for longer term assessment of the needs of cancer patients and the best means of addressing those needs.

In this major new initiative, we applaud your willingness to consult with thought leaders in the provider and patient communities to assure that the assessment tools are most appropriate to the circumstances. A year's worth of well-designed data collection will represent a significant first step toward the sort of information collection that is required to measure quality cancer care, but we would hope that CMS also would be open to extension of the one-year project beyond 2005 in order to move toward a permanent information gathering system. In addition, there may be other information elements that should be collected and assessed for future applications, including, for example, potential coding and reimbursement for chemotherapy management of oral anticancer agents that are increasingly an integral part of modern cancer care.

We deeply appreciate the thoughtful approaches that you have brought to the often difficult topic of reimbursement for cancer chemotherapy services, and we believe that this demonstration project will prove to be the beginning of a new paradigm of quality measurement for cancer care. Thanks very much for your involvement.


Cancer Leadership Council

American Cancer Society
American Society of Clinical Oncology
American Society for Therapeutic Radiology & Oncology, Inc.
Cancer Research and Prevention Foundation
The Children's Cause for Cancer Advocacy
Coalition of National Cancer Cooperative Groups
International Myeloma Foundation
Kidney Cancer Association
The Leukemia & Lymphoma Society
Lymphoma Research Foundation
National Coalition for Cancer Survivorship
North American Brain Tumor Coalition
Ovarian Cancer National Alliance
Pancreatic Cancer Action Network
Sarcoma Foundation of America
The Susan G. Komen Breast Cancer Foundation
Us Too International Prostate Cancer Education and Support Network
Y-ME National Breast Cancer Organization