A Call for Action: Medicare Sets Q1 2005 Physician IVIG Payment Rate at $40.02/gram
As deeply concerned physicians, patient advocacy groups and others continue to press for a fair and workable Medicare IVIG payment policy, CMS has published a "payment allowance limit" of $40.02 per gram of IVIG, coded as J1563. The applicable period for this payment rate is January 1, 2005 through March 31, 2005.
This rate is based on third quarter 2004 average selling prices (ASPs) reported by manufacturers of all IVIG products to CMS, consistent with the new Medicare Prescription Drug, Improvement and Modernization Act (DIMA) enacted into law in December 2003. The $40.02 payment rate represents this ASP plus 6%. The payment rate is to be updated quarterly, based on the manufacturer ASP for all IVIG products.
Factors not considered in this new Medicare payment policy include:
- The substantial variability in pricing for different IVIG preparations and delivery forms;
- Costs associated with claims preparation, billing and collection;
- Distribution-related costs; and
- Non-access of physicians to discounts and rebates available to hospitals and large group purchasing entities.
FFF is working diligently with other industry stakeholders to change this inequitable payment policy, and we are asking for your help on this critical issue. Here is how you can help:
Write to CMS to explain how the new Medicare IVIG payment policy will affect you and your patients. Your comments must be received before 5:00 p.m. EST on Friday, January 14.
- Submit your comments electronically to http://www.cms.hhs.gov/regulations/ecomments. (Attachments should be in Microsoft Word, WordPerfect or Excel format).
To provide your comments, go to the line which identifies Docket No. CMS-1429-FC. Then click on the word "Go" to submit your comments.
- Please copy FFF on your comments via email to kbgressitt@fffenterprises.com or call Kit-Bacon Gressitt at 1-800-843-7477.
Your input is needed to convince Medicare that IVIG products constitute a special class of human therapeutics that require a different reimbursement policy in order to assure continuing patient access in the physician office setting.
Use New "G" Codes to Bill Your Medicare Infusion/Injection Services
Effective January 1, Medicare requires that providers use a new set of temporary "G" codes for billing infused and injected drugs and hydration solutions.
For IVIG, the old CPT code 90780 is replaced with G0347 (IV infusion for therapy/diagnosis, initial, up to one hour). And, old CPT code 90781 is replaced with two codes: G0348 (each additional hour, up to eight hours) and G0349 (additional sequential infusion, up to one hour; list separately in addition to code for primary procedure). In 2006, these temporary "G" codes will be replaced with new CPT codes.
Your billing staff should check with other insurers to determine whether to bill with 90780/90781 or G0347/G0348/G0349.
More detailed information about the entire series of "G" product administration codes is published in the November 15, 2004 Federal Register, starting on page 66305.
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