ASPS on Medicare Part B Drug Proposal
In October, the Centers for Medicare & Medicaid Services’ (CMS) Center for Medicare and Medicaid Innovation (“Innovation Center”) unveiled a new plan to reduce Medicare’s costs for Part B prescription drugs, or those drugs that are not typically self-administered (e.g., infusions or injections) as part of a doctor’s service. The Medicare Part B drug market has changed significantly in the past ten years. Higher cost drugs, particularly biologicals manufactured by sole sources, are driving an increase in Part B drug expenditures.
While on the surface this does not appear to impact most plastic surgery offices, ASPS found it troubling that the Innovation Center proposed mandatory participation for physicians in randomly selected geographic areas. The plan also includes a proposal to allow private-sector vendors to negotiate prices for and take title to drugs. Notably, CMS proposes to phase down the Medicare payment amount for selected Part B drugs to more closely align with prices paid by other developed nations.
Under this “international price index” model, physicians would be required to enroll with at least one model vendor and obtain drugs from a model vendor for administration to Medicare beneficiaries. Additionally, physicians would have to follow model-specific billing instructions to submit claims.
In partnership with the Alliance of Specialty Medicine, ASPS provided comments to the Innovation Center regarding the scope and size of the proposal, as well as the unintended consequences this policy might have on patient access to medications should reimbursement policy reward practitioners for administering lower-cost drugs. ASPS expects the Innovation Center to take the next several months to review feedback, with a revised document made public before 2nd quarter 2019.