This compliance evaluation is limited to patients who received treatment from August 1, 2009 through December 31, 2009 (eligible patients).

The compliance threshold at the current time is 80% for both treatment and supportive care. Treatment compliance is based on the sum of all compliant patients and is inclusive of the following solid tumors and hematologic malignancies:

• Solid Tumors: Breast, lung, colon, prostate and ovarian carcinoma
• Hematologic Malignancies: Multiple myeloma, CLL, mantle cell lymphoma, follicular lymphoma, and large B-cell lymphoma

Overall compliance rates for treatment are determined by the sum of all eligible patients with the solid tumors and hematologic malignancies listed above. For supportive care, compliance is the sum of all compliant patients across anemia, neutropenia, and anti-emetic therapies for which there is a pathway divided by the sum of all eligible patients. Although individual physician compliance scores have been provided, program compliance will be based on the aggregate score of all physicians within your practice. You can view the diagnosis codes used to define the tumor types, as well as a list of antineoplastic agents used in determining treatment compliance by clicking the filter box on the compliance portal (p4pathways.com). If an antineoplastic agent was administered to a given patient and it was not part of an approved regimen, then that patient was determined to be non-compliant. Antineoplastic agents in a regimen must have been administered within a 30-day period of time to be considered part of the regimen. Therapeutic agents may be held or dropped from a regimen and the patient would still be considered compliant, but the addition of an agent to an approved regimen will be considered a new line of therapy or treatment.

Compliance measurement is based on information taken from claims and remittance files. Each physician will have the ability to view his/her personal compliance score as well as the overall score for the practice and entire physician network. We have also provided the total number of CareFirst patients that were seen by you and the impact that the special fee schedule may have on your practice depending on your level of compliance. If you have not achieved compliance at this time with both pathway categories, you will have the opportunity to improve your score prior to having your special fees reduced. The critical period for this determination will occur for eligible patients with a date of service between August 1, 2009 through May 31, 2010 or March 1, 2010 through May 31, 2010, whichever is higher. The new special fee will go into effect August 1, 2010.

In the “Noncompliant Patients” section of the reporting website you will be able to view a list of your non-compliant patients and the reason for that determination. The reasons for non-compliance are listed below by category:

Chemotherapy Treatment:

• Treatment off-pathway: A list of agent(s) will be provided that were administered to a given patient that resulted in this finding.
• Excessive lines of treatment: Some of the pathways have limits on the number of lines of therapy that can be provided.

Anemia:

• ESA dosing exceeds pathway limits: Dosing limits are 100mcg per week for Aranesp® and 40k units per week for Procrit® given in any combination of dose and week. A fifty percent dosage increase is allowed after four weeks.

Neutropenia:

• Administration of a WBC growth factor with chemotherapy that has a low risk (<10%) of febrile neutropenia. A documented prior FN event will allow for the administration of a WBC growth factor with a low FN risk chemotherapy regimen.

Anti-emesis:

• A 5HT3 or Emend® administration when given with chemotherapy which has a low emetogenic potential (Hesketh 2 or below). A documented uncontrolled N/V response in a previous cycle would allow for a 5HT3 or Emend® to be used for low emetogenic chemotherapy.

In limited cases, available data may be missing important information that would mitigate an adverse compliance determination for a specific patient. With this in mind, we have provided the ability for you to submit additional information on-line that would reverse a non-compliance determination. Examples of missing information that may reverse a non-compliance determination are included below:

• A patient with multiple diagnoses which required additional agents that would be considered non-compliant for his/her primary diagnosis.
• Chemotherapy dosing factors that would affect supportive care.
• Use of oral medications that were not reported by your practice on the fax form which required the use of additional supportive care agents.
• Patient was on a clinical trial which was not reported on the fax form.
• Patient was in hospice care which was not reported on the fax form.
• Patient has been treated by multiple practices.
• Patient had a documented uncontrolled N/V event previously in response to an agent or regimen having a Hesketh score of 2 or below.
• Patient received radiation or surgery that would affect the level of supportive care provided.
• An erroneous practice Tax ID or CareFirst physician rendering number was used in the compliance analysis.
• Patient chemotherapy and/or supportive care were delivered in multiple types of facilities (hospital, outpatient facility, or office).
• Erroneous medical billing by the practice.
• Disagreement with the Hesketh score or FN risk level assigned to a particular antineoplastic agent or regimen.
• Other mitigating factors that would affect an adverse compliance determination.

In the “Noncompliant Patients” section of the website, click on “Reconcile” following a specific patient’s name or ID number to provide additional information which would allow a compliance physician to review and determine compliance status. Once submitted, the patient’s status will change to “Pending”, after which you will receive an email from us with the final compliance determination.