HFMA Comments on CMS’s Part B Drug Payment Model Proposed Rule
HFMA submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the changes proposed to Medicare’s reimbursement methodology for separately payable Part B drugs contained in “Medicare Program; Part B Drug Payment Model; Proposed Rule,” published in the March 11, 2016, Federal Register.
HFMA discussed members’ specific concerns regarding the following proposals included in the rule:
- CMS’s articulation of the problem and the resulting solution identified
- CMS’s legal authority to conduct a pilot of this scope
- Financial impact on providers
- Beneficiary access to care and cost sharing
- Unnecessarily increased administrative complexity
- Impact to CMS Shared Savings programs and other similar initiatives
- Applicability of pharmaceutical value-based payment models to the Medicare program