The Regulatory & Reimbursement Policy Landscape in Personalized Medicine: A (Payer s) Perspective

Similar documents
Reimbursement for Advanced Diagnostics: Challenges and Opportunities

Coding and Payment for Genomic Sequencing Procedures (GSPs) and Existing Advanced Diagnostic Laboratory Tests (ADLTs)

NEWSFLASH: Quorum Consulting s Guide to the Medicare Clinical Diagnostics Laboratory Tests Payment System Final Rule.

Pre Market Reimbursement Strategies for New Technologies

From Research to Revenue Coverage and Reimbursement for Life Sciences Products

ASSESSING THE VALUE OF MEDICAL DEVICES CHOOSING THE BEST PATH FORWARD: WHERE DO WE GO FROM HERE? Drew Baker GO FROM HERE?

Regulation of CDx under the new In Vitro Diagnostics Regulation

Legislative & Regulatory Issues Facing Pathology & Laboratory Medicine. Ronald L. Weiss, MD

PAMA. How Did We Get Here and What s Next? Current Reimbursement Issues: Regulatory Trends, Market Dynamics, and Strategies Post-PAMAgeddon

2.05 Predictive Modeling P4P and Physician Engagement. Pay for Performance Summit February 7, 2006

Prior Authorization, Pharmacy and Health Case Management Information. Prior Authorization. Pharmacy Information. Health Case Management

Evaluating the Value of New Drugs and Devices

Legislative Symposium

Molecular Diagnostic Solutions for Urologic Cancer

CMS Proposes New Medicare Reporting and Payment System for Laboratories

Overview of Reimbursement Strategies for Novel Medical Technologies

Market Access Strategy and Planning: Succeeding in the Age of Value-based Reimbursement

William Blair 35 th Annual Growth Stock Conference. June 9, 2015 NYSE: Q. Copyright 2014 Quintiles

Moderator: J van Loon,MSc Mapi. Advisor to the President, Head of International Affairs, HAS France

Solicitation of Public Comments on the Protecting Access to Medicare Act (PAMA)

Medicare Program; Request for Information Regarding the Physician Self-Referral Law. AGENCY: Centers for Medicare & Medicaid Services (CMS), HHS.

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C FORM 10-K

The Impact of Future Healthcare Reform on MedTech Communications

MEDICARE S PAMA-BASED CLFS PAYMENT IMPACT: STRATEGIES TO PROTECT YOUR LAB S REVENUE LÂLE WHITE, EXECUTIVE CHAIRMAN AND CEO, XIFIN, INC.

Medicare Part C Medical Coverage Policy

Payer's Goals for Pre-Authorization, Medical Necessity, and Pricing for Molecular and Genetic Tests. Trisha Brown, MS, LCGC Shama Consulting, LLC

The Road to Market Access

April 26, Are Payers Getting Tougher? Essential Insights on How to Smooth Acceptance of New Genetic Tests?

Leveraging Real-World Data and Analytics in the Device Industry. Tom Abbott Head, Healthcare Informatics Medical Device & Diagnostics

Challenges in Reimbursing Orphan Medicinal Products. Evaluating Benefit, Determining a Fair Price and Optimizing Access

Contractor Information. LCD Information. FUTURE Local Coverage Determination (LCD): Molecular Diagnostic Tests (MDT) (L33541)

June 30, 2006 BY ELECTRONIC DELIVERY

The Fundamentals of Reimbursement

WILLIAM BLAIR GROWTH STOCK CONFERENCE JUNE 12, 2018 CHICAGO, IL

MYRIAD GENETICS, INC. (Exact name of registrant as specified in its charter) Delaware (State or other jurisdiction

Laboratory Oversight and Enforcement

Public Consultation on The Introduction of a Fee Based Funding Model to Support the Conduct of Medical Device Regulatory Activities by the Health

Update. The authors of this article are all consultants with Huron Consulting Group, which serves the continuum of life sciences organizations

Co-financing mechanisms Budget cap Pay back Risk-sharing instruments Reimbursement tax

BUNDLED PAYMENTS IN RADIATION ONCOLOGY

Welcome. AMCP Partnership Forum. Designing Benefits and Payment Models for Innovative High Investment Medications

Glossary. Adults: Individuals ages 19 through 64. Allowed amounts: See prices paid. Allowed costs: See prices paid.

RISK SHARE AGREEMENTS

REPORT OF THE COUNCIL ON MEDICAL SERVICE. (J. Leonard Lichtenfeld, MD, Chair)

MEDICAL DEVICE REIMBURSEMENT PRESENTED AT ST. THOMAS UNIVERSITY, DESIGN AND MANUFACTURING IN THE MEDICAL DEVICE INDUSTRY COURSE ON SEPTEMBER 30, 2013

Medically Unlikely Edits (MUE)

Innovations: Using a Clinical Pharmacist as a Vehicle for Successful P4P Outcomes

Ambulance Policy. Approved By 7/12/2017

Device Congress. Track B: Reimbursement. How to Convince the Medical Director Your Product is Special

Avalere Health 2015 Industry Outlook

Age to Diagnosis Code & Procedure Code Policy

Therapeutic Goods Amendment (Pharmaceuticals Transparency) Bill Senate Finance and Public Administration Committee

See Important Reminder at the end of this policy for important regulatory and legal information.

Medicare Program; Medicare Shared Savings Program: Accountable Care Organizations Proposed Rule

9/23/2016. Our Services. Transitioning from Fee-for-Service to Value-based Reimbursement. Key Trends and Strategies for Rural Health Providers

Disease Management and the Medicare Drug Benefit: Opportunities and Threats for the Pharmaceutical Industry

THE LINK BETWEEN FDA APPROVAL OF MEDICAL DEVICES AND REIMBURSEMENT

Medicare Patient Access to Technology: The Lewin Group

Medicaid Managed Care 101: Building a Common Understanding for the Healthy Students, Promising Futures Learning Collaborative

Value-based Contracting: Chief Medical Officer and Actuarial Perspectives

The Cost of Specialty Drugs: Payer Perspectives

Intersecting roles CMS and FDA implications for pharmaceutical and device industries

THE WORLD S BEST HEALTH CARE?

EU REA adoption at national level

Today s Payers and Providers

August 27, Dear Ms. Tavenner,

Problems with Current Health Plans

PMB Review: What s next? Evelyn Thsehla Clinical Researcher

Moda Health Reimbursement Policy Overview

Ambulance Policy, Professional

The Case For Value ACA to MACRA to MIPS

Medically Unlikely Edits (MUE)

About AMDD. ISPOR 8 th Asia Pacific Conference Issue Panel 21: A New Challenge Application Rule A promising star or mare s-nest?

Overview of Pharmaco- Economics Methodologies Maher Hassoun, M.S.

FIVE WAYS TO HANDLE HIGH-DEDUCTIBLE PATIENTS IN YOUR MEDICAL PRACTICE

MedTech Innovation Amid Changing Dynamics for Insurers, Hospitals, and Consumers

HEALTHCARE COMMON PROCEDURE CODING SYSTEM (HCPCS) LEVEL II CODING PROCEDURES

Re: CY 2018 CLFS - Preliminary Payment Rates and Crosswalking/Gapfilling Determinations; Comments submitted to

Demonstrating Value of Medicines Through Health Economic and Outcomes Evidence

Re: Medicare Prescription Drug Benefit Manual Draft Chapter 5

Disclosures and Analyst Certifications can be found in Appendix A.

Healthcare Value Purchasing: Perspectives from Employers, Facilities and Consumers

What Regulatory Requirements are Responsible for the Transactions Standards?

HOW DO I EVENTUALLY GET PAID? Phillip Ward, DPM CPT Advisor, CPT Assistant Editorial Panel Member

Re: Medicare Prescription Drug Benefit Manual Draft Chapter 6

Clinical Trials Corporate Medical Policy

EFFICIENCY AND TRANSPARENCY IN PRICING

Cigna Administrative Policy

Valuation of Alternative Payment Models

Professional/Technical Component Policy, Professional

The HPfHR 3-Tier System

CANCER LEADERSHIP COUNCIL

Advanced Analytics. The key to unlocking the Triple Aim and Value-Based Purchasing. Ines Vigil MD, MPH, MBA

than value. infrastructure for value-based payment, it is apparent that greater assumption of

INSTITUTE OF MEDICINE COMMITTEE ON THE DETERMINATION OF ESSENTIAL HEALTH BENEFITS

Issue brief: Medicaid managed care final rule

Documenting to Support. Medical Necessity. for the Pediatric Dental Professional

Risk Contracting: What to Know About Stop Loss Insurance KATHRYN A BOWEN, EXECUTIVE VICE-PRESIDENT OCTOBER 27, 2016

Myriad Genetics Reports Fiscal Fourth-Quarter 2016 Financial Results

Advocating For Reasonable Regulation. Steve Ubl President and CEO, AdvaMed

Transcription:

The Regulatory & Reimbursement Policy Landscape in Personalized Medicine: A (Payer s) Perspective Girish Putcha, MD, PhD Director of Laboratory Science 12 December 2016

Disclaimer Any opinions expressed are my own and not necessarily those of MolDX, Palmetto, or CMS. 2

A vicious cycle for diagnostics LDT and IVD parallel universes Poor and inconsistent coverage and reimbursement Highly variable and non-transparent evidence development Weak and inappropriate clinical adoption 3

A case study in dysfunction: BRACAnalysis CDx Insurers in New Jersey, North Carolina, and Tennessee stopped covering the CDx in favor of less expensive LDTs Indications for use: as an aid in identifying ovarian cancer patients with deleterious or suspected deleterious germline BRCA variants eligible for treatment with Lynparza (olaparib) Variant classification according to a defined classification process by an inhouse committee so will the efficacy and safety of Lynparza be the same in patients identified by the LDTs? Do we know or care? Should we? 4

Regulatory Challenges Almost all commercially available genomic tests are laboratory-developed tests (LDTs). Of 5921 tests registered with MolDX from inception to 9/25/2015, >93% (5512) are LDTs. Many have similar, if not identical, intended use(s) as FDA-cleared or approved tests Limited to no oversight of marketing claims Limited to no transparency for providers, patients, or payers into their quality Evidentiary standards for commercialization are almost entirely self-determined with limited, generally non-transparent independent 3rd party review (e.g., CAP, NYSDOH, health technology assessment (HTA) groups, payers) Is this situation in the best interest of patients? Of innovation? Of healthcare in the US? Why is this appropriate for diagnostics but not for medical devices, drugs, etc? 5

Reimbursement Challenges Coding CPT codes for genomic tests can be over-simplified, failing to recognize clinically important differences among these tests, resulting in their commoditization and undervaluation Obscure unambiguous identification of a test/service by allowing code stacking v2.0 (i.e., by analyte vs methodology) Coverage Idiosyncratically variable despite presumably asking similar if not identical questions based on the same evidence Appropriately focused on clinical utility while inappropriately ignoring analytical and (to a lesser extent) clinical validity, generally deferring to regulatory approval 6

Reimbursement Challenges Payment Unlike some other areas of healthcare, pricing continues to be based on cost instead of market, let alone on value Market-based pricing imminent under PAMA though gaps may remain (e.g., 81479) Core underlying assumption in PAMA is that commercial payers are better (i.e., cheaper) at pricing tests than CMS Impact of value-based models is unclear 7

God, grant me the serenity to accept the things I cannot change, the courage to change the things I can, and the wisdom to know the difference. 8

A virtuous cycle for diagnostics LDTs and IVDs complement, not duplicate, each other Robust and consistent coverage and reimbursement Robust, consistent and transparent evidence development Strong and appropriate clinical adoption 9

Solutions: Regulatory Principles Develop a unified regulatory system in which LDTs and IVDs complement, not duplicate, each other in the marketplace For example, once test with a given intended use is cleared or approved by the FDA, the sales and marketing of LDTs with the same intended use ceases (likely with a sunset period and exceptions for public health, low risk, rare diseases, etc) At an absolute minimum, 3 rd party-assessed AV and CV performance characteristics should be publicly available BEFORE commercial availability Accordingly, CMS (and its approved accreditation organizations and exempt states) continue to focus on process and personnel; FDA on the product, manufacturing, and marketing System should be risk-based, both for the purposes of enforcement discretion and prioritization of reviews during the transitional period Improved transparency of AV and CV performance data (i.e., publicly available and independently assessed), and of ongoing proficiency testing 10

Lessons from the EU s IVDR? Exemptions (i.e., LDTs) Devices manufactured and used only within health institutions if following also met: Not transferred to another legal entity Under appropriate quality management systems Laboratory compliant with EN ISO 15189 The target patient group s specific needs cannot be met or cannot be met at an appropriate level of performance by an equivalent device available on the market. Provisions do not apply to devices manufactured on an industrial scale. 11

Solutions: Coding Develop better codes that recognize clinically important differences among tests that impact their cost and value (because you cannot pay for value or quality if you cannot identify it) PAMA: Advanced diagnostic laboratory test (ADLT) codes and codes that distinguish FDA-cleared/approved tests from LDTs AMA: Proprietary laboratory assay (PLA) codes Clarify appropriate use of codes (e.g., MolDX M00127 and M00130 billing and coding guidelines for NGS panels) Ensure internal consistency of reimbursement (e.g., 81432 at $622.53 and 81162 at $2485.86 on CLFS) and/or eliminate vestigial codes more quickly 12

Solutions: Coverage Transparently define and consistently apply criteria for coverage Apply same CU metrics (e.g., improvement in net health outcomes ) for all healthcare interventions (i.e., diagnostics, therapeutics, physician services, hospital services, etc) so value-based trade-offs designed to optimize both the cost and effectiveness of care are possible Require and specify appropriate comparators: Best practice or real world? Consider risk-sharing approaches (e.g., coverage with evidence development) 13

Solutions: Payment Price all healthcare activities (i.e., diagnostics, therapeutics, physician services, hospital services, etc) transparently using similar value-based (or at least market-based) metrics FFS-based systems misalign incentives for all stakeholders, but especially for patients, providers and payers In a FFS world, reimburse activities commensurate with their value, taking into account the strength and quality of their evidence Stop silo-ing money for different activities so value-based tradeoffs designed to optimize both the cost and effectiveness of care are possible Consider value-based risk-sharing approaches (e.g., reimbursement with evidence development ) 14

Thank you. Questions and comments are always welcome. gputchapmdx@gmail.com 15