Dermatologists are calling on the Centers for Medicare & Medicaid Services to delay implementation of the proposed regulations that will test new payment methods for Medicare Part B drugs.

CMS’s proposed rule is aimed at addressing the rising cost of drugs by targeting how doctors are reimbursed for the drugs that are administered in the physician office.

The agency argues in the proposed rule that the current payment formula – average sales price (ASP) plus 6% – incentivizes the use of expensive drugs over lower-cost alternatives. Therefore, the agency seeks to run a test – half of doctors would continue to receive ASP plus 6%, while others would receive ASP plus 2.5% and a flat fee of $16.80. The proposed rule also would test other value-based tools.

The American Academy of Dermatology Association (AADA) criticized the proposal in written comments submitted May 9. “While the proposal is meant to control Medicare drug spending, it does not address the main factor behind rising health care costs, the increasing cost of drugs,” according to the comment.

“I think [the proposal] needs an indefinite period of delay until the structure and issues can be worked out,” Dr. Sabra Sullivan, a dermatologist from Jackson, Miss., said in an interview. The main issue is the rising drug costs “and this Part B proposed rule really doesn’t address any of that or the price of drugs and how they are fluctuating. It is not just brand name drugs. Many generics [are having the same issue]. We try to use generics, but in many ways generics are costing as much as a brand name.”

Dr. Sullivan said that the rule “really hasn’t been fleshed out with support structures. There’s going to be a big possibility and probability of having many, many unintended consequences, including cutting off drugs to patients that are stable and denying access to drugs to people that need it.”

The AADA noted that “there is the potential for infusions to increasingly be administered at the hospital or infusion centers as opposed to the physician’s office. [The Medicare Payment Advisory Commission] predicted that small and solo practices may have a hard time obtaining expensive drugs for their patients. If it is not financially feasible to administer the drug in the provider’s office, they may direct patients to hospitals. If this is the case, there may be a higher copay for the patient and CMS will likely have to pay more for the administration of the drug in the hospital or infusion centers.”

Dr. Sullivan also challenged the assertion that there is a profit motive connected to the selection of appropriate drugs to administer to patients.

“People aren’t picking drugs because they cost more money and they make a lot of money,” Dr. Sullivan said.

AADA also noted that the proposed test, which would randomly assign zip codes for testing of the proposals, could affect dermatologists with multiple offices.

“Dermatologists often maintain practices at several different locations in order to provide access to a wider group of patients,” AADA noted in its comments. “Rural practices also often have multiple offices to meet the geographical need of patients. CMS’ proposal would require practices with multiple locations to comply with different components of the models, which would be both administratively complex and burdensome. The AADA recommends that CMS more carefully consider the impact of the testing groups on practices and provide an exemption for practices with multiple locations to ensure that all the branches of the practice test the same payment models.”

gtwachtman@frontlinemedcom.com

Ads