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2006 proposed fee schedule - American Society of Clinical Oncology

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131<br />

independent facilities, to account for spending on syringes<br />

that were included in the EPO payments prior to the<br />

implementation <strong>of</strong> the MMA drug payment provisions. In<br />

CY 2005, we estimate payments for these syringes will amount<br />

to $1.6 million for hospital-based facilities and $26.8<br />

million for independent facilities. For CY 2005, we<br />

estimate that total spending, after the deduction <strong>of</strong><br />

payments for syringes, will reach $246 million for Epogen<br />

provided in hospital-based facilities, and $2.850 million<br />

for drugs provided in independent facilities ($1.960 million<br />

for Epogen and $890 million for other drugs). We note that<br />

all other drugs provided in hospital-based ESRD facilities<br />

continue to be paid at cost.<br />

(6) Add-On Calculation and Budget Neutrality<br />

For each <strong>of</strong> the top 10 drugs (as explained below), we<br />

calculated the percent by which ASP +6 percent is projected<br />

to be less than payment amounts under the 95 percent <strong>of</strong> AWP<br />

pricing system for CY 2005. For Epogen, this amount is 7.5<br />

percent. We applied this 7.5 percent figure to the total<br />

aggregate drug payments for Epogen in hospital-based<br />

facilities, resulting in a difference <strong>of</strong> $18 million.<br />

We then calculated a weighted average <strong>of</strong> the<br />

percentages by which ASP +6 percent would be below 95<br />

percent <strong>of</strong> AWP payment prices, for the top 10 ESRD drugs for<br />

independent facilities. We weighted these percentages by

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