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2006 proposed fee schedule - American Society of Clinical Oncology

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259<br />

representing 42 percent <strong>of</strong> the market, which indicated wide<br />

variation across companies in the patient monthly cost <strong>of</strong><br />

dispensing inhalation drugs from a low <strong>of</strong> $7 to a high <strong>of</strong><br />

$204.3 The GAO report indicated that the wide variation in<br />

supplier costs is due, in part, to variation in the services<br />

suppliers <strong>of</strong>fer and that some <strong>of</strong> the costs incurred by<br />

suppliers may not be necessary to dispense inhalation drugs,<br />

for example, marketing, overnight shipping, and 24-hour<br />

hotlines.<br />

In light <strong>of</strong> the substantial changes occurring in<br />

inhalation drug reimbursement in 2005, we viewed 2005 as a<br />

transitional year. With the wide variation in the reported<br />

costs and services provided by inhalation drug suppliers<br />

suggested by the comments and the GAO study, we stated in<br />

last year’s final rule that we would establish an interim<br />

dispensing <strong>fee</strong> for inhalation drugs applicable for CY 2005<br />

and reconsider the issue for CY <strong>2006</strong>. The 2005 dispensing<br />

<strong>fee</strong> for a 30-day supply <strong>of</strong> inhalation drugs was based on the<br />

industry recommended $68 <strong>fee</strong> from AAH study, excluding<br />

certain costs that Medicare generally does not reimburse<br />

regardless <strong>of</strong> the scope <strong>of</strong> the Medicare benefit (that is,<br />

sales and marketing, bad debt, and an explicit pr<strong>of</strong>it<br />

margin). The resulting <strong>fee</strong> established for a 30-day supply<br />

<strong>of</strong> inhalation drugs was $57 for CY 2005. This CY 2005 <strong>fee</strong><br />

3 GAO, “Appropriate Dispensing Fee Needed for Suppliers <strong>of</strong> Inhalation Therapy Drugs,” GAO-05-72, October 2004.

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