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2006 proposed fee schedule - American Society of Clinical Oncology

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251<br />

We also note MedPAC’s recommendation in its June 2005<br />

report that the ASP be the basis <strong>of</strong> payment for all<br />

separately billable ESRD drugs provided by both freestanding<br />

and hospital-based facilities in CY <strong>2006</strong> (MedPAC, “Report to<br />

the Congress: Issues in a Modernized Medicare Program,”<br />

June 2005). In making this recommendation, MedPAC states<br />

that the ASP data are more current (updated quarterly), and,<br />

thus, more likely to reflect actual transaction prices,<br />

compared with acquisition cost data which are not regularly<br />

collected by the OIG or CMS. Furthermore, the report<br />

indicated that utilizing the same payment policy for both<br />

freestanding and hospital-based facilities would ensure<br />

uniformity across the various settings irrespective <strong>of</strong> the<br />

site <strong>of</strong> care. In addition, MedPAC recommends in its report<br />

that we obtain, “…data to estimate hospitals’ costs and<br />

Medicare’s payment per unit for these drugs. No published<br />

source identifies the unit payment for these drugs because<br />

Medicare pays hospitals their reasonable costs.” MedPAC<br />

further states: “We attempted to calculate the unit payment<br />

from 2003 claims data, but the accuracy <strong>of</strong> the data fields<br />

we needed to make this calculation was unclear, particularly<br />

the number <strong>of</strong> units furnished and Medicare’s payment to the<br />

hospital.” MedPAC also recommends that CMS and/or OIG<br />

collect acquisition cost data periodically in the future to

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