FOR INFORMATION CONTACT:
Lori Gardner, Senior Director
Communications & Marketing
301.984.9496 ext. 226
For Immediate Release: October 9, 2006
Association of Community Cancer Centers Releases Comments to CMS About Proposed 2007 Hospital Outpatient Prospective Payment System
ROCKVILLE, Md.—On Friday, October 6, 2006, the Association of Community Cancer Centers (ACCC) submitted comments to the Centers for Medicare & Medicaid Services (CMS) with regard to the proposed 2007 Hospital Outpatient Prospective Payment System and 2007 payment rates.
“ACCC urges CMS to protect cancer patients’ access to quality care in the most appropriate setting by providing appropriate reimbursement for cancer treatments under the Hospital Outpatient Prospective Payment System,” said ACCC Executive Director Christian Downs, JD, MHA. “We believe proposed 2007 Medicare payments of average sales price plus 5 percent will not be sufficient to cover the drug reimbursement and related pharmacy costs in the hospital outpatient setting.”
In its comments, ACCC urged CMS to recalculate payments for separately paid drugs without pass-through status to ensure that all pharmacy service costs associated with those drugs are included in their reimbursement. At a minimum, payment for these drugs should be set at no less than average sales price (ASP) plus 6 percent.
“ACCC believes that CMS’s methodology for determining payment rates for separately payable drugs and their handling costs is deeply flawed,” said Downs. Not only does the methodology fail to recognize that hospitals’ charges might not include their substantial pharmacy handling costs, but, to the extent that those costs are included in hospitals’ charges, it also fails to capture them accurately.
ACCC recommended that CMS continue to study mechanisms to reimburse hospitals for their pharmacy service costs and pay separately for all drugs with Healthcare Common Procedure Coding System (HCPCS) codes, including anti-emetics.
Although ACCC supports CMS’s proposal to make separate payments for additional hours of infusion services, it is concerned by the significant decrease in payment for the first hour codes. ACCC asked CMS to verify that its calculations are correct and that those rates are appropriate.
ACCC also is concerned that the current drug administration codes do not allow additional payment for second IV push of the same drug. If the drug is packaged, hospitals do not receive any payment for the drug’s second administration service. ACCC supports the Panel on APC Groups’ recommendation to make payment for a second or subsequent intravenous push of the same drug by instituting a modifier, developing a new HCPCS code for the procedure, or implementing another methodology.
ACCC also urged CMS to:
- Continue to reimburse separately paid radiopharmaceuticals based on the hospital’s charge adjusted to cost using hospital-specific cost-to-charge ratios.
- Implement the proposed six new ambulatory payment classifications (APCs) for drug administration services as well as the changes recommended by the Advisory Panel on APC Groups to allow hospitals to be reimbursed appropriately for drug administration services.
- Continue to make payment for the preadministration services associated with providing intravenous immune globulin (IVIG).
The full text of ACCC’s comments to CMS are available at: