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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
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