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CMSRulemakingCMS-2008-0073

Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2009; and Revisions to the Amendment of the E Prescribing Exemption for Computer Generated Facsimile Transmissions

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National Association of Chain Drug Stores filings
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National Association of Chain Drug Stores filed 1 comment on this docket between Aug 30, 2008 and Aug 30, 2008. 222 other organizations filed here. The comment window closed 6370d ago.

What National Association of Chain Drug Stores filed (1)

Aug 30, 2008· National Association of Chain Drug Stores (Khani, Julie)--E-PRESCRIBING, ASP, PHYS/NPP ENROLLMENT· CMS-2008-0073-0685

**ALSO ATTACHED AS A PDF FILE*** VIA Electronic Submission August 29, 2008 Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-1403-P (RIN 0938-AP18) P.O. Box 8013 Baltimore, MD 21244-8013 Re: CMS -1403-P: Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2009; and Revisions to the Amendment of the E-Prescribing Exemption for Computer Generated Facsimile Transmissions Dear Sir/Madam: The National Association of Chain Drug Stores (NACDS) appreciates the opportunity to comment on the above proposed rule. We applaud the Centers for Medicare and Medicaid Services' (CMS) proposal on the e-prescription exemption for computer generated facsimile transmission. However, we are concerned that CMS did not propose an update of pharmacy supplying and dispensing fees for CY 2009 for Medicare Part B drugs. We respectfully request CMS to provide the much needed update to these fees in the final rule. We also urge CMS to reconsider the additional requirements it has proposed for Medicare suppliers related to record retention and enrollment. These additional requirements could have negative consequences on Medicare beneficiaries' ability to obtain drugs and services from their local pharmacies. NACDS represents traditional drug stores, supermarkets and mass merchandisers with pharmacies. Its approximately 200 chain member companies include regional chains with a minimum of four stores to national companies. NACDS members also include approximately 1,000 suppliers of pharmacy and front-end products, and approximately 100 international members representing more than 30 countries. Chains operate more than 39,000 pharmacies, and employ a total of more than 2.7 million employees, including 118,000 pharmacists. They fill nearly 2.5 billion prescriptions yearly, and have annual sales of over $750 billion. We provide our comments to help CMS make the Medicare Part B program more successful for our nation's seniors. I. E-Prescription Exemption for Computer Generated Facsimile Transmissions NACDS is eager to see true e-prescribing become commonplace. Computer to computer electronic prescribing has many benefits and efficiencies for the prescriber, pharmacy, and patient. Numerous studies show that e-prescribing is associated with reduced medication errors, increased use of more cost-effective medications such as generics, improved patient compliance, and other savings and benefits. We applaud CMS for encouraging the widespread adoption of e- prescribing. NACDS is pleased to see that the proposed rule reflected comments previously submitted by NACDS as well as those of several of its member companies. It is evident that CMS examined the comments thoroughly and took into consideration the needs of the pharmacy industry. The extra workload that the elimination of auto faxing of refills would have placed on pharmacy staff would have eliminated any benefits gained from the final rule. NACDS welcomes the opportunity to continue to work with CMS on issues to improve adoption of e-prescribing as well as other issues that improve customer service and patient care in our members' pharmacies. II. Average Sales Price (ASP) Issues NACDS is very troubled by CMS' failure to propose an increase in supplying and dispensing fees for Part B drugs for CY 2009 as administrative costs incurred by pharmacies to participate in Part B remain costly and burdensome. In addition, CMS' failure to increase supplying and dispensing fees will leave unmitigated the effects of inadequate reimbursement under the ASP methodology. Some of the administrative and economic challenges pharmacies face due to CMS' policies are examined below. Enrollment issues: Unlike other programs, pharmacies face more administrative costs and inefficiencies with Medicare Part B enrollment. For example, CMS policy requires retail pharmacies to re…

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Abstract

This proposed rule would address proposed changes to Medicare Part B payment policy. We are proposing these changes to ensure that our payment systems are updated to reflect changes in medical practice and the relative value of services. This proposed rule also discusses refinements to resource based practice expense (PE) relative value units (RVUs); geographic practice cost indices (GPCI) changes; malpractice RVUs; requests for additions to the list of telehealth services; several coding issues; payment for covered outpatient drugs and biologicals; the competitive acquisition program (CAP); application of health professional shortage area (HPSA) bonus payments; payment for renal dialysis services; performance standards for mobile independent diagnostic testing facilities; and physician and nonphysician practitioners furnishing diagnostic testing services; a solicitation for comments regarding the use of the Federal Payment Levy Program to recover delinquent Federal tax debts; a proposed amendment to the exemption for computer generated facsimile transmissions from the National Council for Prescription Drug Programs (NCPDP) SCRIPT standard for transmitting prescription and certain prescription-related information for Part D covered drugs prescribed for Part D eligible individuals; conforming and clarifying changes for comprehensive outpatient rehabilitation facilities (CORFs); revisions for rehabilitation agencies; therapy related technical corrections; the physician quality reporting initiative; physician self referral issues and anti markup; beneficiary signature for nonemergency ambulance transport; the chiropractic services demonstration; educational requirements for nurse practitioners and clinical nurse specialists; qualifications of portable x ray supplier personnel; the expiration of provisions of the Medicare, Medicaid, and SCHIP Extension Act of 2007; bonus payments for long ambulance transports; the annual update for clinical laboratory fees under the clinical laboratory fee schedule; physician certification/recertification for home health services; a prohibition concerning providers of sleep tests; organ retrieval; a revision to the “Appeals of CMS or CMS contractor Determinations When a Provider or Supplier Fails to Meet the Requirements for Medicare Billing Privileges” final rule; and, potentially misvalued services under the physician fee schedule.

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