CMS'S USE OF COST-EFFECTIVENESS EVIDENCE IN NCDS FOR PREVENTION

Author(s)

Chambers JD, Neumann PJTufts Medical Center, Boston, MA, USA

OBJECTIVES: The U.S. Centers for Medicare and Medicaid Service’s (CMS’s) stated policy is that it does not use cost-effectiveness evidence in National Coverage Determinations (NCDs).  This position appeared to be reinforced in the recent U.S. Patient Protection and Affordable Care Act (PPACA) which, while not explicitly prohibiting the use of cost-effectiveness evidence, barred the use of cost-per QALY thresholds in coverage decisions.  The objective of this study is to review CMS NCDs made since the enactment of PPACA (March 23, 2010) to determine whether and how CMS has used cost-effectiveness evidence in its decision-making. METHODS: We reviewed the decision memorandum for each NCD from March 23, 2010, through December 2011.  We documented any mention of cost-effectiveness evidence.  On occasions when cost-effectiveness evidence was used or cited in CMS’s review, we reviewed the decision memorandum to identify the legislative authority cited. RESULTS: Since March 23, 2010, CMS have made 18 NCDs.  Cost-effectiveness evidence was used only in the 4 of the 18 NCDs pertaining to preventative care (i.e., in the 14 NCDs pertaining to non-preventative care, cost-effectiveness was not mentioned).  In two instances, cost-utility studies (reporting cost-per QALY ratios) featured in CMS’s review.  In the remaining two instances, cost-effectiveness was reported using “cost-per additional depression free day” and “cost-per case treated”.  A cost-per QALY threshold was not discussed in any decision memo.  In each instance, the legislative authority used for the inclusion of cost-effectiveness evidence was the Medicare Improvement for Patients and Providers Act (MIPPA) of 2008 (which grants CMS authority to “conduct an assessment of the relation between predicted outcomes and the expenditures.”) CONCLUSIONS: The findings suggest that CMS is routinely considering cost-effectiveness evidence in NCDs for preventative care.  Consistent with the PPACA legislation, a cost-per QALY threshold was not used.

Conference/Value in Health Info

2012-06, ISPOR 2012, Washington, D.C., USA

Value in Health, Vol. 15, No. 4 (June 2012)

Code

HC4

Topic

Health Policy & Regulatory

Topic Subcategory

Reimbursement & Access Policy

Disease

Multiple Diseases

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