HFMA submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the changes proposed to Medicare’s reimbursement methodology for separately payable Part B drugs contained in “Medicare Program; Part B Drug Payment Model; Proposed Rule,” published in the March 11, 2016, Federal Register

HFMA discussed members' specific concerns regarding the following proposals included in the rule:

  • CMS’s articulation of the problem and the resulting solution identified
  • CMS’s legal authority to conduct a pilot of this scope
  • Financial impact on providers
  • Beneficiary access to care and cost sharing
  • Unnecessarily increased administrative complexity
  • Impact to CMS Shared Savings programs and other similar initiatives
  • Applicability of pharmaceutical value-based payment models to the Medicare program