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CMS-1403-FC
of 2008 was extended to the entire year, and the mid-year
2008 rate reduction of -10.6 percent was retroactively
replaced with the rates in effect from January through June
2008. They were further relieved that in lieu of the
estimated -15 percent update that would otherwise have
applied for 2009, the MIPPA specified a 1.1 percent update
for CY 2009. However, these commenters remain concerned
about the estimated negative update for CY 2010 of
approximately -21 percent, followed by multiple years of
negative physician updates of approximately -5 percent.
Commenters described how they believe the SGR and update
formulas are flawed, and they urged us to work with the
Congress to develop a new methodology. Some commenters
suggested using our administrative authority to lessen the
negative impact by removing drugs from the SGR, accounting
for NCDs in the allowed expenditures targets, and reducing
the productivity adjustment to the MEI.
Response: Ultimately, the formula for the SGR and the
physician update are dictated by statute. We are required
to follow this methodology when calculating the payment
rates under the PFS. We look forward to working with the
Congress, the physician community, and other interested
parties as we continue to analyze appropriate alternatives
to the current system that could ensure appropriate
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