The Medicare Payment Advisory Commission (MedPAC) at its November meeting discussed a draft recommendation that the Secretary of Health and Human Services (HHS) should clarify requirements for reporting the impact of drug bundling in calculating the average sales price (ASP). The Centers for Medicare & Medicaid Services (CMS) had sought comment about how drug bundling affects ASP calculation and sales of Part B drugs but took no action on this issue in its recently released final 2007 Medicare Physician Fee Schedule.
Rather than recommending a specific allocation method, MedPAC staff and members expressed interest in preserving the integrity of the ASP-based system for reimbursement of Part B drugs. They also commented that bundling could affect oncologists’ treatment decisions. “Some physicians believe that the practice is hurting their ability to choose a product based on clinical decisions” rather than financial incentives, according to Joan Sokolovsky, PhD, a MedPAC staff analyst who reported on this issue.
Specifically, “many oncologists spoke about a particular example of…bundling that created a problem for them,” said Dr. Sokolovsky. A pharmaceutical firm that makes product A in a crowded therapeutic category may discount a unique, single-source agent to oncology practices that choose product A over its competitors. This creates a financial incentive for oncologists to choose a particular product for which there are alternatives.
MedPAC’s draft recommendation, to be voted on next month, states, “Discounts should be allocated in a way that does not create inappropriate financial incentives for clinicians…and ensures that the ASP reflects the true average transaction price.”
http://www.medpac.gov/public_meetings/transcripts/1108_1109_medpac.final.pdf
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