DHPA today submitted a comment letter to the Centers for Medicare & Medicaid Services on the Medicare Program Hospital Outpatient Prospective Payment System (OPPS) Remedy for the 340B-Acquired Drug Payment Policy for Calendar Years 2018-2022 (Proposed Rule).
In its comment letter DHPA requested CMS to announce as part of the “remedy” for the 340B-acquired drug payment policy that the Agency is going to conduct a survey of drug acquisition costs and use the findings from that survey to establish an accurate payment level for 340B hospitals on a prospective basis rather than continue to pay 340B hospitals at the unsupportable level of Average Sales Price (ASP) + 6 percent.
The comment letter also agreed with CMS’s proposal to decrease the OPPS conversion factor prospectively to ensure that hospitals do not reap a windfall from the inflated reimbursement levels they received for non-drug items and services from CY 2018 through CY 2022 when 340B hospitals were paid at ASP minus 22.5%, but argued that a 0.5% downward adjustment to the conversion factor over 16 years is too long a period for recouping the inflated reimbursement that CMS paid over a five-year period. DHPA recommended that CMS modify its proposal so that the “fix” occurs over five years—the same length of time that the conversion factor was artificially inflated as a result of payment to 340B hospitals at ASP minus 22.5 percent.
Click here to read the full letter >>