MetroHealth Issues Public Comment on Centers for Medicare & Medicaid Services Rule
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In 2019,
These figures inform our approach to improving health outcomes. At
Our comments address CMS' proposal to further reduce payments to safety net hospitals, especially those participating in the 340B Program. Treating a high volume of Medicaid and low-income Medicare patients,
We rely on our 340B Program savings to meet the needs of the low-income patients we serve, including Medicare beneficiaries, and the current Medicare 340B Program payment cuts have directly impacted our ability to provide needed care to low-income patients. We urge CMS to consider the consequences of the MFN model on safety-net hospitals serving the nation's vulnerable patients, as well as the vulnerable beneficiaries they serve.
CMS' MFN model will have further negative implications for patient access to lifesavings drugs. CMS currently reimburses providers for separately payable Part B drugs, which are administered in our hospital outpatient departments, at Average Sales Price ("ASP") plus 6 percent. Since 2018, we have been reimbursed at 77.5 percent of ASP for 340B drugs--a policy we have been against since it was first proposed because it redistributes reimbursement from safety net hospitals to non-safety net hospitals. We purchase Part B drugs primarily from drug wholesalers, administer or dispense them to the patient, and then bill Medicare for the drug. The types of drugs we administer and bill under Part B include lifesaving injectable drugs, intravenous cancer drugs, immunosuppressive drugs, and hemophilia blood clotting factors.
Through the MFN model, CMS will tie the payment for 50 drugs to the lowest international price from a group of 22
In CMS' illustrative list of the lowest
These losses will be even more pronounced for safety net hospitals and would deprive them of their ability to receive discounts and realize savings as intended under the 340B statute. The program, codified in section 340B of the Public Health Service Act, was created by
Under the 340B program, covered entities can purchase certain outpatient drugs at discounted prices, enabling savings that are critical to the operations of hospitals that fill a safety-net role. The 340B program is structured by statute to provide hospitals discounts for covered outpatient drugs, regardless of the receiving patient's insurance status.
By grossly underpaying providers for Part B drugs without exerting pressure on manufacturers to lower their prices, CMS would deprive 340B hospitals like
Astoundingly, CMS estimates that the MFN Model will lead to "reduced beneficiary access through 340B providers" and predicts nearly
Further, by CMS' own estimate, by the end of the second year of the model, nearly 20 percent of Medicare beneficiaries will lose access to needed Part B drugs. At least a portion of the estimated savings attributable to this model would be due to beneficiaries "not accessing their drugs through the Medicare benefit."/6
It is entirely irresponsible to implement a new payment system that would eliminate beneficiary access.
We recommend the MFN rule be withdrawn. By withdrawing the model and preserving access to 340B discounts, CMS will ensure safety-net hospitals can continue to use their limited resources to provide access to affordable, lifesavings drugs, and improve health outcomes for vulnerable populations.
Please contact
Sincerely,
Executive Vice President, Chief Operating Officer
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Footnotes:
1/ 85 Fed. Reg. 76180 (
2/
3/ H.R. Rep. No. 102-384, pt. 2 (1992).
4/ 85 Fed. Reg. 76180, 76229.
5/ Id. at 76239.
6/ Id. at 76237.
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The rule can be viewed at: https://www.regulations.gov/document?D=CMS-2018-0132-2750
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