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2006 proposed fee schedule - American Society of Clinical Oncology

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will ensure that the level <strong>of</strong> aggregate payments to ESRD<br />

facilities is maintained. We note that our proposal to<br />

allow some facilities to move directly to the new wage-<br />

170<br />

adjusted composite rate will have some impact on the level<br />

<strong>of</strong> the budget neutrality adjustment. However, we estimate<br />

that the overall effect on total payments to facilities<br />

would not be significant. For example, the impact on<br />

aggregate payments to rural facilities would be a decrease<br />

<strong>of</strong> about 0.2 percent and an increase <strong>of</strong> about 0.1 percent<br />

for urban facilities. This occurs because all <strong>of</strong> the<br />

facilities that are currently subject to the 1.300 wage<br />

index cap are located in urban areas.<br />

We also considered alternative approaches for<br />

transitioning facilities to the <strong>proposed</strong> updated wage<br />

adjustments. Another approach would be to apply the<br />

<strong>proposed</strong> 50-50 transition to all facilities, whether or not<br />

they do better using the updated wage index adjustment.<br />

This approach would treat all facilities equally for<br />

transition purposes, but would mean that those facilities<br />

that are currently underpaid because <strong>of</strong> the current outdated<br />

wage index adjustment would have to wait until the<br />

transition was completed to receive the higher payment to<br />

which they are entitled.<br />

An alternative to the <strong>proposed</strong> two-year transition<br />

would be to adopt a three-year transition. This would allow

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