- Allowing physicians to remain in the current buy-and-bill system.
- Ensuring a minimum of three vendor choices per physician.
- Allowing physicians to easily switch between vendors and/or back to the current buy-and-bill system.
- Prohibiting CAP vendors from engaging in any utilization management techniques or medical review work.
The American Gastroenterological Association, which also supported to the Alliance of Specialty Physicians suggestions, said in separately filed comments that it is “unclear that the marketplace has changed in ways that would support the success of a new CAP program,” though the AGA “does not oppose” the idea of a new, voluntary CAP program.
The AGA noted that consolidation has improved the negotiation and purchasing power of physicians in the Part B space, while practices that remained independent as small and mid-sized groups “mostly shifted their Part B drug and biologic patients to hospital outpatient–based departments and infusion clinics because of the significant upfront costs of administering Part B drugs and biologics.”