COA Formal Comments on 2021 HOPPS Proposed Changes

Re: Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs; New Categories for Hospital Outpatient Department Prior Authorization Process; Clinical Laboratory Fee Schedule: Laboratory Date of Service Policy; Overall Hospital Quality Star Rating Methodology; and Physician-Owned Hospitals (CMS-1736-P) Dear Administrator Verma: On behalf of the Board of Directors of

By |2022-09-01T13:23:18-04:00October 2nd, 2020|Comment Letters|0 Comments

COA Telehealth in Cancer Care Position Statement

Community Oncology Alliance Position Telehealth has become a valuable component in the care of patients with cancer during the COVID-19 (novel coronavirus) pandemic. Telehealth offers evaluation and treatment when an in-person visit is ill-advised, impractical, or otherwise unavailable. This could be because of issues such as patient safety and health status, geographic limitations, transportation

By |2022-09-01T13:30:45-04:00September 24th, 2020|Position Statements, Research & Publications|0 Comments

COA Demand Letter to CVS Caremark

Re: Illegal “Slow Rolling” and “Pretextual Denials” of Applications by Dispensing Physicians Seeking Admission into CVS Caremark’s Pharmacy Networks Dear Ms. Buchanan: As you are aware, Frier Levitt is counsel to the Community Oncology Alliance (“COA”). We trust you are familiar with the COA organization as a non-profit dedicated to advocating for dispensing physicians and

By |2022-09-01T13:23:19-04:00September 18th, 2020|Comment Letters|0 Comments

COA Comments on Medicaid Drug Rebate Rule

Re: Medicaid Program; Establishing Minimum Standards in Medicaid State Drug Utilization Review (DUR) and Supporting Value-Based Purchasing (VBP) for Drugs Covered in Medicaid, Revising Medicaid Drug Rebate and Third Party Liability (TPL) Requirements (CMS-2482-P) Dear Administrator Verma: On behalf of the Board of Directors of the Community Oncology Alliance (“COA”), I am submitting this

By |2022-09-01T13:23:19-04:00July 21st, 2020|Comment Letters|0 Comments

COA Certificate of Need Requirements Position Statement

Community Oncology Alliance Position The Community Oncology Alliance (COA) opposes the Certificate of Need (CON) requirements because they can limit patient access to important cancer care services, such as imaging and radiation therapy. CON driven limitations in services create hardship in accessing local treatments, patients’ choice of providers, and fragments the care teams when

By |2022-09-01T13:30:46-04:00June 23rd, 2020|Position Statements, Research & Publications|0 Comments

COA Copay Accumulator Programs Position Statement

Community Oncology Alliance Position The Community Oncology Alliance (COA) opposes copay accumulator programs because they artificially prevent patients in cancer treatment, who need financial assistance, from meeting their deductibles, thereby keeping out-of-pocket costs for drugs artificially high. As a result of the higher out-of-pocket costs, many patients soon find the cost of cancer care

By |2022-09-01T13:30:46-04:00June 23rd, 2020|Position Statements, Research & Publications|0 Comments

COA Comments to CMS on COVID-19 Policy and Regulatory Revisions

Re: Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency (CMS-1744-IFC) Dear Administrator Verma: On behalf of the Board of Directors of the Community Oncology Alliance (“COA”), I am submitting this comment letter to the Centers for Medicare & Medicaid Services (“CMS”) in response to the Medicare and

By |2022-09-01T13:23:19-04:00May 18th, 2020|Comment Letters|0 Comments

2020 Community Oncology Alliance Practice Impact Report

1,748 Community Oncology Clinics and/or Practices Have Closed, Been Acquired by Hospitals, Merged, or Reported Financial Struggles Since 2008 Significant Increase in Community Oncology Practice Mergers and/or Acquisitions with Other Non-Hospital Practices or Corporate Entities as Hospital Acquisitions Continue The 2020 Community Oncology Alliance (COA) Practice Impact Report tracks the changing landscape of community

Community Oncology Alliance Requests Oncology Care Model (OCM) Extended Through 2021

Re: Oncology Care Model Dear Deputy Administrator & Director Smith: On behalf of the Board of Directors of the Community Oncology Alliance (“COA”), we are reaching out to express concern about the impact of complications related to the novel coronavirus (“COVID-19”) pandemic on participants in the Oncology Care Model (“OCM”), and to request immediate action

By |2022-09-01T13:23:20-04:00April 10th, 2020|Comment Letters|0 Comments