This week, ASCRS and members of the Alliance of Specialty Medicine sent a letter to the Centers for Medicare & Medicaid Services (CMS) on its recent Notice of Benefit and Payment Parameters for 2019, expressing concern over access to specialty medical care in Marketplace plans. CMS proposes to rely on states and private accrediting organizations to assess network adequacy of Marketplace plans. This is problematic because states are not equipped to ensure network adequacy and accreditation organizations have no enforcement capability. Furthermore, the qualified health plans are similar to Medicare Advantage plans that rely on claims and administrative data to generate physician performance scores, which do not make fair comparisons and are ultimately used to justify elimination of many specialists from networks.
In addition, CMS proposes to establish a national benchmark standard plan for prescription drugs. We expressed significant concern that a national benchmark standard plan for medicines, likely influenced by financial considerations rather than clinical data, would limit provider and patient access to needed medications. We will keep you updated.