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CMS-1403-FC
In the CY 2009 PFS proposed rule, we noted that the
Office of the Inspector General’s (OIG) study on the
availability and pricing of IVIG published in a April 2007
report entitled, “Intravenous Immune Globulin: Medicare
Payment and Availability (OEI-03-05-00404),” found that for
the third quarter of CY 2006, just over half of IVIG sales
to hospitals and physicians were at prices below Medicare
payment amounts. Relative to the previous three quarters,
this represented a substantial increase of the percentage
of sales with prices below Medicare amounts. During the
third quarter of 2006, 56 percent of IVIG sales to
hospitals and over 59 percent of IVIG sales to physicians
by the largest 3 distributors occurred at prices below the
Medicare payment amounts. We reviewed national claims data
for IVIG drug utilization as well as utilization of the
preadministration–related services HCPCS code. The data
show modest increases in the utilization of IVIG drugs and
the preadministration-related services code, which suggest
that IVIG pricing and access may be improving.
In the CY 2009 PFS proposed rule, we noted that these
factors, taken as a whole, suggested a lessening of the
instability of the IVIG market. As a result of these
developments, we proposed to discontinue the
preadministration-related service payment in 2009 for HCPCS
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