2006 proposed fee schedule - American Society of Clinical Oncology

gauge the appropriate percentage of ASP for the payment
amount.
252
While we acknowledge MedPAC’s recommendations, we are
proposing to make payment using the ASP +6 percent
methodology for all separately billed ESRD drugs furnished
in freestanding facilities and for EPO furnished in
hospital-based facilities. Paying for EPO furnished in
hospital-based facilities using the ASP +6 percent
methodology is consistent with past practices where we have
paid for EPO in hospital-based facilities consistent with
freestanding facilities. That is, in 2005, we paid for EPO
in hospital-based facilities based on acquisition costs
consistent with freestanding facilities. While we are not
proposing to pay for drugs other than EPO furnished in
hospital-based facilities under the ASP +6 percent
methodology at this time, we are interested in moving to
this approach. We believe that it is more appropriate to
pay for separately billed drugs furnished in hospital-based
facilities under the ASP +6 percent methodology rather than
on a reasonable cost basis, as we believe that there should
be consistency across sites in payment for the same item or
service. However, we have not made this proposal due to the
lack of data regarding drug costs and expenditures
associated with hospital-based ESRD payments. We have
discussed a potential approach to making estimates of these