No Room for Regulatory Uncertainty in Cancer Care

Many community cancer practices offer patients integrated care, which meets the medical, emotional, and social needs of a patient. It allows patients to access comprehensive cancer care services all under one roof – including chemotherapy, radiation therapy, nutrition guidance, financial counseling, psychological support, and medically-integrated dispensing (MID). In short, integrated care is the gold standard for treating patients.

MID is a critical part of integrated care for many cancer patients. It enables them to get oral chemotherapy prescriptions directly from their cancer care practice. The same medical team that delivers a patient’s in-clinic cancer treatment also dispenses the oral medication the patient takes between treatment visits.

Because oral medication doses and formulations require close monitoring, frequent medication adjustments are common. MID allows practices to mail or deliver patient medications to their home. The patient gets the adjusted prescription quickly, without traveling back to the clinic between treatment appointments or transferring a prescription to a pharmacy outside the integrated care setting. Not surprising, practices with medically integrated pharmacy services have been shown to significantly improve patient medication adherence, reduce time to treatment, and improve outcomes at a lower cost.

MID has been disrupted by Medicare regulatory uncertainty. The Centers for Medicare and Medicaid Service (CMS) recently reinterpreted regulation and announced that practices that deliver prescriptions to their patients’ homes are in violation of federal physician self-referral law. The penalties for such violations are strict – fines, prison, and a ban on treating all Medicare patients. As a result, this element of integrated patient care is in jeopardy. When one pillar of integrated care is disrupted, the patient, provider, and caregiver are immediately affected.

Patients, providers, and caregivers have appealed to Congress for resolution to the uncertainty and disruption to care that CMS created. The Seniors’ Access to Critical Medications Act of 2023 (H.R. 5526) would clarify that delivering medicines by mail, courier, or other methods, or allowing a family member or caregiver to pick up medicines on behalf of a patient, would not violate federal law.

Prohibiting MID is not in the best interest of patient care, medical outcomes, efficiency, or program cost. MID puts patient need, not bureaucracy, first. Patients and Providers United prioritizes keeping patients, providers, and caregivers at the center of medical decision making. For that reason, Patients and Providers United supports efforts to advance H.R. 5526.

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