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2006 proposed fee schedule - American Society of Clinical Oncology

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approaches for obtaining these data. However, we seek<br />

138<br />

comment about a potential method to estimate the drug add-on<br />

amount for drugs furnished in hospital-based facilities, and<br />

we seek comment about alternative estimation methodologies,<br />

data, or both.<br />

One estimation approach could be an approach where the<br />

pricing spread for drugs other than EPO furnished in<br />

hospital based facilities would be assumed to be the same as<br />

for those drugs in independent facilities. This aggregate<br />

approach would assume that the add-on amount for drugs other<br />

than EPO furnished in hospital-based facilities results in<br />

the same relative amount <strong>of</strong> drugs furnished as for those<br />

drugs in independent facilities. Using aggregate ratios,<br />

the drug add-on amounts calculated for drugs other than EPO<br />

furnished in independent facilities might be extrapolated<br />

for drugs other than EPO furnished in hospital-based<br />

facilities.<br />

Use <strong>of</strong> this approach could allow calculation <strong>of</strong> a<br />

reasonable estimate <strong>of</strong> aggregate drug add-on amount for<br />

drugs other than EPO furnished in hospital-based facilities<br />

until the time that data becomes available to more<br />

accurately calculate the drug add-on adjustment. This<br />

approach would allow payment <strong>of</strong> all drugs furnished in<br />

hospital-based facilities under the ASP +6 percent payment<br />

methodology, achieve consistent payments for ESRD separately

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