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

code G0332. For CY 2009, under the Outpatient Prospective<br />

Payment System (OPPS), a proposal was made to package<br />

payment for HCPCS code G0332 (73 FR 41457).<br />

The following is a summary of the comments received<br />

and our responses.<br />

Comment: We received several comments from<br />

beneficiaries, patient advocate groups, manufacturers, and<br />

physicians. Most commenters opposed the elimination of the<br />

preadministration-related services payment. A few<br />

commenters requested that the preadministration-related<br />

services payment become permanent for both the PFS and the<br />

OPPS. Some commenters stated that the market conditions<br />

for IVIG are not fundamentally different than they were<br />

when <strong>CMS</strong> initially instituted the preadministration-related<br />

services payment in CY 2006. The commenters requested that<br />

<strong>CMS</strong> continue the separate payment until there is more<br />

stability in the IVIG market. Several commenters stated<br />

that the information <strong>CMS</strong> presented in the CY 2009 PFS<br />

proposed rule did not conclusively prove that the IVIG<br />

market was stabilizing. The commenters stated that<br />

significant access problems remain.<br />

In response to the findings of the OIG report, some<br />

commenters stated that the lag inherent in the ASP pricing<br />

system may have played a role in substantially increasing<br />

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