The Association for Clinical Oncology has submitted comments to CMS over concerns that work requirements included in the agency’s interim final rule, published June 1, would increase administrative burden for both cancer patients and physicians.
Under HR 1, low-income, nonpregnant adults ages 19 to 64 must work, perform community service or attend school — or some combination of these — for at least 80 hours a month to keep Medicaid coverage.
To qualify for a medical frailty exemption, a beneficiary must be diagnosed with one of five conditions: blindness or disability, substance use disorder, a disabling mental disorder, a physical or developmental disability that impairs activities of daily living, or a serious or complex medical condition. An exemption will not be based on diagnosis alone; the diagnosed condition must also significantly impair the beneficiary’s ability to meet the 80-hour monthly requirement.
ASCO’s concerns, detailed in a letter addressed to CMS Administrator Mehmet Oz, MD, include:
- Ensuring a cancer diagnosis alone is sufficient for an exemption from work requirements.
- Removing the need for cancer patients to perform functional capacity tests to prove medical frailty.
“Confirming functional capacity will likely require physician or another form of attestation, creating additional burdens on Medicaid enrollees, states and physicians, which contradicts the legislative language and the goals of this Administration to reduce paperwork burden,” the letter said. - Opposing a requirement that would see oncologists performing work-capacity evaluations, which would introduce clinical liability and ethical conflicts, the group said.
- Urging CMS to expand hardship exemptions for caregivers of cancer patients.
- Asking CMS to explicitly grant automatic exemptions from community engagement requirements to:
- Individuals undergoing testing for a cancer diagnosis.
- Patients in active cancer treatment.
- Cancer survivors undergoing active surveillance for long-term side effects or disease recurrence.
- Caregivers supporting individuals through testing, active treatment, or surveillance.
Read the full letter here.
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