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

patient utilization growth. We indicated that this<br />

methodology would be used to update the drug add-on to the<br />

composite rate until such time that we had sufficient ESRD<br />

drug expenditure data to project the growth in ESRD drug<br />

expenditures beginning in CY 2010.<br />

For CY 2009, we proposed revising the interim<br />

methodology for estimating the growth in ESRD drug<br />

expenditures by using ASP pricing instead of the PPI to<br />

estimate the price component of the update calculation.<br />

As detailed below in this section, we proposed for CY<br />

2009 to estimate price growth using historical ASP pricing<br />

data for ESRD drugs for CY 2006 through CY 2008, and to<br />

estimate growth in per patient utilization of drugs by<br />

using ESRD facility historical drug expenditure data for<br />

CY 2006 and CY 2007.<br />

b. Estimating Growth in ESRD Drug Prices<br />

For CY 2009, we proposed to estimate price growth<br />

using ASP pricing data for the four quarters of CY 2006 and<br />

CY2007, and the two available quarters of CY 2008. For<br />

this final rule with comment period, we are using four<br />

quarters of ASP prices for CYs 2006, 2007, and 2008. We<br />

calculated the weighted price change, for the original top<br />

ten ESRD drugs for which we had acquisition pricing, plus<br />

Aranesp. In CY 2006 and CY 2007, we calculated a weighted<br />

167

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