2019 Comment Letters

Oncology Care First

Pacific Business Group on Health (PBGH) provided input on the proposed oncology payment model, tentatively labelled Oncology Care First. PBGH believes that value-based payment will only work if it reflects improvements in patient outcomes, and we are encouraged that the Center for Medicare & Medicaid Innovation (CMMI) continues to propose innovative payment models that are keyed to measured improvements in patient health outcomes. In this comment letter, PBGH outlined a staged measure adoption process that can be implemented within the design of a new oncology payment model and which will help oncology practices shift to outcomes-based purchasing, payment, and contracting. This process entails:

• Sequencing measures used for oncology payment incentives to encourage continually increasing capabilities for collection of ePROs
• Assuring that providers understand and use ePROs in patient care
• Building infrastructure to allow for risk adjustment and reporting

The comment letter can be read in its entirety here.

Lower Health Care Costs Act

Elizabeth Mitchell sent a letter to the Senate HELP Committee on Tuesday, following her influential testimony at the Committee’s hearing on June 18. She continued to push for an end to surprise billing (including air ambulances), a reasonable benchmark for physician payments, reductions in drug costs, prohibitions on anti-competitive provider contracting terms, increased transparency (including for PBMs), and improvements in maternal and child health.

Read and listen to PBGH President and CEO Elizabeth Mitchell’s testimony before the U.S. Senate HELP Committee on June 18th and hear her share how care should and can be high quality and affordable.

Members of PBGH join other employers and health care purchasers to stop the unfair and harmful surprise billing that takes place due to no fault of patients accessing health care that they believe is in-network or for which they have no choice. Read more here.