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CMS-1403-FC
average price reduction of 1.8 percent. We also calculated
a weighted average price reduction of 2.1 percent between
CY 2007 and CY 2008. The overall average price reduction
is 1.9 percent over the 3-year period. Thus, the weighted
average ESRD drug pricing change projected for CY 2009 is a
reduction of 1.9 percent.
Comment: Commenters were generally opposed to the use
of ASP prices to estimate the price component of the drug
add-on adjustment. One commenter stated that although the
price of EPO has declined in the past few years, it has now
stabilized and will likely not decline again in CY 2009.
Two commenters, including MedPAC, supported the use of ASP
prices stating that it is more closely related to the
actual ESRD drug pricing than the use of the overall drug
PPI. Another commenter stated that the PPI was a more
accepted proxy for predicting drug price increases compared
to ASP price trends which have never been used in
forecasting drug price changes. Some suggested that we use
a blend of ASP and PPI to soften the impact of the change
in the methodology.
Response: Given that the statutory language mandates
that we estimate the growth in ESRD drug expenditures in
order to update the drug add-on adjustment, we believe we
have an obligation to utilize the best data available to
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