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

make those estimates. Although the PPI is a well<br />

recognized measure of overall drug price growth, it is not<br />

specific to ESRD drug prices. Given that ESRD drug pricing<br />

trends are very different from overall drug pricing trends,<br />

we do not believe it would be appropriate to continue using<br />

the PPI when more specific data are available. ASP pricing<br />

data that are specific to ESRD drugs provide the most<br />

accurate measure for estimating the price component of the<br />

total ESRD drug expenditure estimate for CY 2009.<br />

Therefore, for this final rule with comment period, we used<br />

ASP pricing data to estimate price growth in ESRD drugs.<br />

c. Estimating Growth in Per Patient Drug Utilization<br />

To isolate and project the growth in per patient<br />

utilization of ESRD drugs for CY 2009, we removed the<br />

enrollment and price growth components from the historical<br />

drug expenditure data, and considered the residual to be<br />

utilization growth. As discussed previously in this<br />

section, we proposed to use ESRD facility drug expenditure<br />

data from CY 2006 and CY 2007 to estimate per patient<br />

utilization growth for CY 2009.<br />

We first estimated total drug expenditures for all<br />

ESRD facilities. For the CY 2009 PFS proposed rule<br />

(73 FR 38528), we used the final CY 2006 ESRD claims data<br />

and the latest available CY 2007 ESRD facility claims,<br />

169

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