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CMS-1403-FC E. Specific Coding Issues Related to the Physician Fee Schedule 1. Payment for Preadministration-Related Services for Intravenous Infusion of Immune Globulin In the CY 2009 PFS proposed rule (73 FR 38518), we proposed to discontinue payment for HCPCS code G0332, Services for intravenous infusion of immunoglobulin prior to administration (this service is to be billed in conjunction with administration of immunoglobulin), for services furnished after December 31, 2008. Immune globulin is a complicated biological product that is purified from human plasma obtained from human plasma donors. In past years, there have been issues reported with the supply of intravenous immune globulin (IVIG) due to numerous factors including decreased manufacturing capacity, increased usage, more sophisticated processing steps, and low demand for byproducts from IVIG fractionation. When IVIG is furnished to a patient in a physician’s office, three different payments are usually recognized: payment for the IVIG product itself (described by a HCPCS J code); payment for the administration of the IVIG product (described by one or more CPT codes); and similar payment for the preadministration-related services (HCPCS code 122

CMS-1403-FC G0332). The Medicare payment rates for IVIG products are established through the Part B average sales price (ASP) drug payment methodology. As explained in detail in the CY 2006, CY 2007 and CY 2008 PFS final rules with comment period (70 FR 70218 to 70221, 71 FR 69678 to 69679, and 72 FR 66254 to 66255, respectively), we created, in 2006, a temporary code in order to pay separately for the IVIG preadministration-related services in order to assist in ensuring appropriate access to IVIG during a period of market instability. Part of this instability was due to the implementation of the new ASP payment methodology for IVIG drugs which began in 2005. The payment for preadministration-related services was continued in 2007 and 2008 because of continued reported instability in the IVIG marketplace. The preadministration-related payment was designed to pay the physician practice for the added costs of obtaining adequate supplies of the appropriate IVIG product and scheduling the patient infusion during a period of market uncertainty. The PFS rates for the pre-administration service codes were $72, $75, and $75 respectively in 2006, 2007, and 2008. 123

<strong>CMS</strong>-1403-FC<br />

G0332). The Medicare payment rates for IVIG products are<br />

established through the Part B average sales price (ASP)<br />

drug payment methodology.<br />

As explained in detail in the CY 2006, CY 2007 and CY<br />

2008 PFS final rules with comment period (70 FR 70218 to<br />

70221, 71 FR 69678 to 69679, and 72 FR 66254 to 66255,<br />

respectively), we created, in 2006, a temporary code in<br />

order to pay separately for the IVIG<br />

preadministration-related services in order to assist in<br />

ensuring appropriate access to IVIG during a period of<br />

market instability. Part of this instability was due to<br />

the implementation of the new ASP payment methodology for<br />

IVIG drugs which began in 2005. The payment for<br />

preadministration-related services was continued in 2007<br />

and 2008 because of continued reported instability in the<br />

IVIG marketplace. The preadministration-related payment<br />

was designed to pay the physician practice for the added<br />

costs of obtaining adequate supplies of the appropriate<br />

IVIG product and scheduling the patient infusion during a<br />

period of market uncertainty.<br />

The PFS rates for the pre-administration service codes<br />

were $72, $75, and $75 respectively in 2006, 2007, and<br />

2008.<br />

123

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