The Medicare Payment Advisory Commission’s (MedPAC) recent report to Congress recommended requiring that patient hemoglobin levels be recorded on claims for erythroid growth factors such as epoetin alfa and darbepoetin alfa. Medicare payments for these growth factors rose from 2004 to 2005, while its expenses for chemotherapy drugs declined during that period. The US Food and Drug Administration has recommended a target hemoglobin level in cancer patients of ≤12 g/dL, and that growth factor be withheld if hemoglobin >13 g/dL, according to the MedPAC report. Data regarding hemoglobin values should be used as part of Medicare’s pay-for-performance initiative, the commission said.
Practice Manager Insider editorial board members Elaine L. Towle, CMPE, and Patricia P. Falconer, MBA, both predicted that this requirement would mean headaches for oncology offices. “The recommendation to include hemoglobin levels on growth factor claims will have a huge effect on office-based oncologists and will add one more hurdle to successful submission of clean claims to Medicare,” said Towle.
Falconer, president of Health Options, “strongly disagree[d]” with the recommendation. “This additional data requirement will add administrative costs to both the medical practices and the CMS [Centers for Medicare & Medicaid Services] intermediary.” She added that the recommended requirement “suggests that physicians are not adhering to clinical guidelines in their use of growth factors.” Guidelines for growth factor use are available from both the American Society of Clinical Oncology and the National Comprehensive Cancer Network, Falconer pointed out. “If CMS wants to address anemia management as part of Medicare’s pay-for-performance initiative, then CMS should add the anemia diagnoses to the current 13 diagnosis profiles in the demonstration project for 2006 and collect data on the utilization of growth factors and adherence to clinical guidelines,” she advised.
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