ACCC Testifies; CMS HOP Panel Agrees
On Feb. 27, 2012, the Association of Community Cancer Centers (ACCC) testified at the new Advisory Panel on Hospital Outpatient Payment (HOP) meeting. In the 2012 Hospital Outpatient Prospective Payment System rule, CMS replaced the Ambulatory Payment Classification (APC) Panel with the newly expanded HOP Panel. Among this panel’s duties is to serve as the independent review entity that will consider stakeholder requests for assignment of supervision levels other than direct supervision for specific outpatient therapeutic services.
Former ACCC President Ernest R. Anderson, Jr., MS, RPh, testified on behalf of ACCC before the HOP Panel and CMS staff. ACCC asked the panel to make four recommendations to CMS related to future rulemaking in the Hospital Outpatient Prospective Payment System (HOPPS):
- To pay for separately payable drugs at ASP+6 percent
- To freeze the packaging threshold at $75
- To remove 340B data from the calculation of the ASP+ rate
- To require all hospitals to bill all drugs with a HCPCS code under revenue code 0636.
ACCC believes that all of these recommendations, especially when taken together, will allow CMS to gather better data while paying hospitals more appropriately for drugs and pharmacy overhead costs. ACCC has often participated in a larger group of “pharmacy stakeholders,” but this year we testified on our own. Although the other groups supported ACCC’s testimony, they decided not to present publically.
After a short discussion, the HOP panel agreed with ACCC and recommended to CMS all four of our recommendations. CMS does not have to adopt the HOP Panel’s recommendations, but ACCC is hopeful that the agency will take them into consideration when drafting the 2013 Proposed HOPPS Rule.
ACCC will be following up with CMS staff in meetings in the coming months. Stay tuned.