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

For CY 2009, we proposed no update to the per<br />

treatment drug add-on amount of $20.33 established in<br />

CY 2008.<br />

3. Update to the Drug Add-On Adjustment<br />

In the CY 2009 PFS proposed rule (73 FR 38529), we<br />

estimated a 1 percent reduction in per patient utilization<br />

of ESRD drugs for CY 2009. Using the projected decline of<br />

the CY 2009 ASP pricing for ESRD drugs of 1.9 percent, we<br />

projected that the combined growth in per patient<br />

utilization and pricing for CY 2009 would result in a<br />

negative update equal to -2.9 percent (0.99 * 0.981 =<br />

0.971). However, we proposed to apply a zero percent<br />

update to the drug add-on adjustment and maintain the<br />

$20.33 per treatment drug add-on amount for CY 2009 that<br />

reflects a 15.5 percent drug add-on adjustment to the<br />

composite rate for CY 2009.<br />

In addition, for CY 2009 we presented an alternative<br />

approach to the zero percent update. The alternative<br />

approach would be to apply an adjustment of less than 1.0<br />

to the drug add-on adjustment. For CY 2009, we would<br />

“increase” the drug add-on by 0.971. Applying the 0.971<br />

increase to the $20.33 per treatment adjustment would yield<br />

a drug add-on amount of $19.74 per treatment, which<br />

represents a 0.4 percent decrease in the CY 2008 drug<br />

173

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