Will CMS Fix the IRA for Community Oncology Before It’s Too Late?
When Congress passed the Inflation Reduction Act (IRA), policymakers hoped to lower drug costs for Medicare beneficiaries. While that goal is widely shared, the implementation of the law—particularly under the Centers for Medicare & Medicaid Services’ (CMS) recently proposed guidance for the 2028 initial price applicability year (IPAY)—risks severely destabilizing the very health care providers who care for the majority of Americans facing cancer.
Reimbursement Realities: A Looming Reimbursement Crisis
Under the current plan for implementing the IRA in Medicare Part B, reimbursement would be tied to the new Maximum Fair Price (MFP). But the mechanism proposed to adjust provider payment undercuts community oncology practices by removing key safeguards.
An Avalere analysis shows that, under this model, reimbursement could be slashed by nearly half—averaging 47%, and in some cases, up to 64%.1 These reductions are not theoretical: they would hit practices already struggling with years of underpayment, rising inflation, and workforce shortages. For independent practices that operate with narrow margins, particularly in rural and underserved areas, this would be unsustainable.
Unlike large hospitals with diverse revenue streams, community oncology practices rely heavily on the current drug reimbursement system to support operations, from highly trained staff to infusion centers and specialized storage. CMS’s proposed approach overlooks these operational realities.
Independent practices are deeply embedded in the communities they serve. They are often more nimble, more affordable, and more accessible than their hospital-based counterparts. Yet, if these practices are faced with such a devastating revenue cut, they will be forced to reduce services, stop offering certain care, or shut down altogether. If this happens, patients will face longer wait times, increased travel burdens, and higher costs of care in the hospital setting.
There is also a broader cancer system impact. Community oncology practices serve the majority of patients in the US. They are integral to clinical trials and active and eager participants in value-based care delivery models, such as the Enhancing Oncology Model (EOM). Weakening what is legitimately the backbone of our cancer care ecosystem will have ripple effects that are difficult to comprehend.
A Simple Technical Fix: COA’s Appeal to Policymakers
The Community Oncology Alliance (COA) recently issued a comment letter to CMS warning of unintended consequences of this top-down bureaucratic program.2 As we said bluntly: “If the IRA is not fixed before 2028, the community cancer care system will be devastated.” The word “devastated” wasn’t hyperbole—it was judgment born of direct feedback from practice owners across the country.
In our formal comments to CMS we outline concrete, feasible steps that can preserve the savings of the IRA drug price negotiations without undermining practices. Specifically, we urge the following actions:
- Congress should pass the Protecting Patient Access to Cancer and Complex Therapies Act.3 The bill is a simple technical fix that would remove providers from the middle of the pricing equation.
- Protect patients enrolled in Medicare Advantage plans, including prohibiting the use of step therapy or other utilization management tools on negotiated Part B drugs.
- Commit to transparency, timeliness, and accountability in the IRA and any new reimbursement systems to ensure providers can rely on consistent payment without undue bureaucracy.
These steps aren’t radical, they’re pragmatic. Practices can’t serve Medicare beneficiaries if they vanish. A ready, accessible community oncology network saves lives and is more cost effective than mega hospitals and health systems.
A Critical Crossroad
The goal of improving affordability is important. However, it cannot come at the cost of the nation’s independent, community oncology system that delivers value and access to patients in communities across the country, including big and small, urban and rural, privileged and underserved.
As CMS considers the feedback it has received on the IRA and 2028 implementation in Part B, it faces a clear choice: maintain rigid adherence to a flawed formula that penalizes community providers—or make adjustments that ensure the success of both the IRA and the broader Medicare program.
Clinical Pathway Category: Business
This column highlights the potential disruption to community oncology practices caused by Medicare’s implementation of the Inflation Reduction Act, threatening access to evidence-based, cost-effective care central to clinical pathways. By advocating for policy adjustments, it reinforces the need to sustain practice viability to ensure consistent pathway adherence, treatment continuity, and equitable oncology care delivery.
References
1. Sullivan M, Tripp A, Isaiah E, Diskey R. IRA Medicare Part B negotiation shifts financial risk to physicians. Avalere Health. November 29, 2022. Accessed July 11, 2025. https://advisory.avalerehealth.com/insights/ira-medicare-part-b-negotiation-shifts-financial-risk-to-physicians
2. Community Oncology Alliance. Community Oncology Alliance responds to draft guidance for Medicare drug price negotiations. June 26, 2025. Accessed July 11, 2025. https://mycoa.communityoncology.org/news-updates/press-releases/coa-responds-to-draft-guidance-for-medicare-drug-price-negotiations
3. Community Oncology Alliance. COA applauds technical fix to IRA drug pricing policy that threatens cancer care. July 9, 2025. Accessed July 11, 2025. https://mycoa.communityoncology.org/news-updates/press-releases/coa-applauds-technical-fix-to-ira-drug-pricing-policy


