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 ...
CMS-1403-FC updated through December 31, 2007 (that is, claims with dates of service from January 1 through December 31, 2007, that were received, processed, paid, and passed to the National Claims History File as of December 31, 2007). For this final rule with comment period, we are using additional updated CY 2007 claims with dates of service for the same time period. This updated CY 2007 data file will include claims received, processed, paid, and passed to the National Claims History File as of June 30, 2008. For the CY 2009 PFS proposed rule, we adjusted the December 2007 file to reflect our estimate of what total drug expenditures would be using the final June 30, 2008 bill file for CY 2007. The net adjustment we applied to the CY 2007 claims data was an increase of 12.6 percent to the December 2007 claims file. To calculate the proposed per patient utilization growth, we removed the enrollment component by using the growth in enrollment data between CY 2006 and CY 2007. This was approximately 3 percent. To remove the price effect, we calculated the weighted change between CY 2006 and CY 2007 ASP pricing for the top eleven ESRD drugs. We weighted the differences using 2007 ESRD facility drug expenditure data. This process led to an overall 1.8 percent reduction in price between CY 2006 and CY 2007. 170
CMS-1403-FC After removing the enrollment and price effects from the expenditure data, the residual growth would reflect the per patient utilization growth. To do this, we divided the product of the enrollment growth of 3 percent (1.03) and the price reduction of 1.8 percent (1.00 - 0.018 = 0.982) into the total drug expenditure change between 2006 and 2007 of 0 percent (1.00 – 0.00 = 1.00). The result is a utilization factor equal to 0.99 or 1.00 / (1.03 * 0.982) = 0.99. Since we observed a 1 percent drop in per patient utilization of drugs between CY 2006 and CY 2007, we projected a 1 percent drop in per patient utilization for ESRD facilities in CY 2009. Comment: A few commenters suggested that the use of CY 2007 billing data to predict utilization change in CY 2009 is not accurate since the utilization change in CY 2007 was driven by a revision to the EPO monitoring policy which caused a one-time decline in utilization that has since leveled off. Response: We agree that the revised monitoring policy for erythropoesis stimulating agents (ESAs) that took effect in CY 2007 could have contributed to the observed decrease in ESRD drug utilization between CY 2006 and CY 2007, especially given that EPO and Aranesp make up over 171
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<strong>CMS</strong>-1403-FC<br />
updated through December 31, 2007 (that is, claims with<br />
dates of service from January 1 through December 31, 2007,<br />
that were received, processed, paid, and passed to the<br />
National Claims History File as of December 31, 2007). For<br />
this final rule with comment period, we are using<br />
additional updated CY 2007 claims with dates of service for<br />
the same time period. <strong>This</strong> updated CY 2007 data file will<br />
include claims received, processed, paid, and passed to the<br />
National Claims History File as of June 30, 2008.<br />
For the CY 2009 PFS proposed rule, we adjusted the<br />
December 2007 file to reflect our estimate of what total<br />
drug expenditures would be using the final June 30, 2008<br />
bill file for CY 2007. The net adjustment we applied to<br />
the CY 2007 claims data was an increase of 12.6 percent to<br />
the December 2007 claims file. To calculate the proposed<br />
per patient utilization growth, we removed the enrollment<br />
component by using the growth in enrollment data between CY<br />
2006 and CY 2007. <strong>This</strong> was approximately 3 percent. To<br />
remove the price effect, we calculated the weighted change<br />
between CY 2006 and CY 2007 ASP pricing for the top eleven<br />
ESRD drugs. We weighted the differences using 2007 ESRD<br />
facility drug expenditure data.<br />
<strong>This</strong> process led to an overall 1.8 percent reduction<br />
in price between CY 2006 and CY 2007.<br />
170