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CMS-1403-FC
four quarters of ASP pricing data are available. We
calculated the weighted price change for the top eleven
ESRD drugs. Tables 8 and 9 show the average ASP prices and
the 2007 weights used. We note that the final CY 2007
weights are derived from the final CY 2007 ESRD facility
claims file as of June 30, 2008. For CY 2006 and CY 2007,
we calculated a weighted average price reduction of
1.8 percent. We also calculated a weighted average price
reduction of 1.9 percent between CY 2007 and CY 2008. The
overall average price reduction is 1.8 percent over the
3-year period. Thus, the weighted average ESRD drug
pricing change projected for CY 2009 is a reduction of
1.8 percent.
We project that the combined growth in per patient
utilization and pricing of ESRD drugs for CY 2009 would
result in a negative update equal to -1.8 percent
(1.00 * 0.982 = 0.982). If we implement this decrease in
the update to the drug-on adjustment, the resulting savings
would have been $14 million. However, as indicated above,
for this final rule with comment period, we are applying no
update to the drug add-on adjustment for CY 2009. Thus, we
are applying a zero update to the $20.33 per treatment drug
add-on amount for CY 2009. After adjusting for the MIPPA
changes as discussed earlier in this section, the final
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