Notice: This CMS-approved document has been submitted - Philips ...

CMS-1403-FC
documentation that did not include specific pricing
information. We also noted that if acceptable
documentation was not received within the proposed rule’s
60-day comment period, we would use prices from the
Internet, retail vendors, and supply catalogs to determine
the appropriate cost; and, that we would use the lowest
price identified by these sources. Table 25 in the
proposed rule lists the top 65 high-cost supplies over $150
which needed specialty input for price updates.
Comment: We received many comments on our proposed
process. Some commenters expressed support for our
proposal but others thought the process was flawed and
burdensome. Some commenters stated that the third year of
the 4-year transition of the PE RVUs to the bottom up
methodology is an inappropriate time to update pricing and
also believed that the repricing of only the high-cost
supplies over $150 is unfair. MedPAC and others
recommended that we use an independent entity to update
this pricing information in order to capture the “average
transaction prices” that reflect the discounts and rebates
offered by the manufacturers. Some commenters submitted
data on the high-cost supplies listed on the table. Of the
65 high cost supplies listed, we received data on 53.
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