19.02.2013 Views

Notice: This CMS-approved document has been submitted - Philips ...

Notice: This CMS-approved document has been submitted - Philips ...

Notice: This CMS-approved document has been submitted - Philips ...

SHOW MORE
SHOW LESS

Create successful ePaper yourself

Turn your PDF publications into a flip-book with our unique Google optimized e-Paper software.

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

to the hospital and away from the physicians’ offices,<br />

presumably reflecting increasing availability of IVIG and<br />

appropriate payment for the drug in both settings.<br />

According to information on the Plasma Protein<br />

Therapeutics Association (PPTA) Web site regarding the<br />

supply of IVIG, in the past year, while the supply <strong>has</strong><br />

spiked at various times throughout the year, the supply <strong>has</strong><br />

remained above or near the 12-month moving average. While<br />

we acknowledge that the supply is only one of several<br />

factors that influence the market, we believe that an<br />

adequate supply is one significant factor that contributes<br />

to better access to IVIG for patients.<br />

Therefore, because we believe that the reported<br />

transient market conditions that led us to adopt the<br />

separate payment for IVIG preadministration-related services<br />

have improved, we believe that continuation of the separate<br />

payment for preadministration services beyond CY 2008 is not<br />

warranted.<br />

After consideration of the public comments received, we<br />

are finalizing our CY 2009 proposal, without modification,<br />

to discontinue separate payment under the PFS for IVIG<br />

preadministration-related services described by HCPCS code<br />

G0332. The treatment of payment for preadministration-<br />

related services under the OPPS will be addressed separately<br />

in that final rule. We will continue to work with IVIG<br />

stakeholders to understand their concerns regarding the<br />

130

Hooray! Your file is uploaded and ready to be published.

Saved successfully!

Ooh no, something went wrong!