4) We will not release any information identifying hospitals or individual respondents without obtaining prior consent.

Transcription

1 Welcome! On July 13, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule that would substantially reduce how much Medicare Part B pays 340B hospitals for non-retail drugs under the Outpatient Prospective Payment System (OPPS). The proposal would apply to non-retail separately payable drugs without pass through status. Such drugs are currently reimbursed at Average Sales Price (ASP) plus 6 percent, the same rate that is used for drugs furnished in non- 340B hospitals. The proposal would lower the rate for 340B hospitals to ASP minus 22.5 percent, a total payment reduction of 27 percent (27% reflects how much of the total payment would be cut after the ASP reduction, including 22.5% of ASP and the 6% of ASP add-on). These changes would be effective January 1, Note that this proposal only applies to hospitals paid under the OPPS and would not affect critical access hospitals. The purpose of this survey is for hospitals to evaluate the financial and operational impact the proposed changes would have on their institutions and their ability to serve low-income and rural patients. Please carefully note the following: 1) This survey may have been sent to more than one contact at your hospital. It is imperative that you coordinate with other stakeholders of the 340B program at your hospital to ensure that you complete only ONE SURVEY PER HOSPITAL. 2) There are 20 questions in the survey. You may wish to review the PDF version of the survey available in the you received before starting so you have the necessary information readily available. 2) Once you click "next" on any page, your responses to questions on the previous page are automatically saved. Should your computer time out or should there be any need to return to the survey at a later date to edit or finish, please note that you can do so, until you hit "DONE" on the last page of the survey. Once the survey is completed, you CANNOT return to edit your responses. 3) The survey can be filled out on your computer, tablet, or smartphone. However, you must complete the survey on the SAME DEVICE that you start the survey on. For example, if you start the survey on your computer, you cannot access your responses to the survey on your smartphone or tablet; you must return to that same computer to complete the survey. Otherwise, you will be prompted to restart the survey. 4) We will not release any information identifying hospitals or individual respondents without obtaining prior consent. 5) The proposed changes do not apply to critical access hospitals (CAHs), as they are not 1

2 reimbursed through the OPPS. If you represent a CAH, PLEASE DO NOT COMPLETE THIS SURVEY. We ask that you complete the survey by August 11th. If you have any questions regarding the survey, please contact Bharath Krishnamurthy at or bharath.krishnamurthy@340bhealth.org. 2

3 General Questions & Demographics * 1. Please indicate what type of hospital your organization is registered as in the 340B program. (Note: If your organization is part of a health system, please complete one survey per hospital. Thank you for your cooperation!) Disproportionate Share Hospital Freestanding Cancer Hospital Rural Referral Center Sole Community Hospital Freestanding Children's Hospital 3

4 General Questions & Demographics 2. Our understanding is that CMS's proposal will not reduce reimbursement for children's and cancer hospitals if they receive OPPS hold harmless payments from Medicare. Although you may not yet know whether you will receive hold harmless payments next year, you may be likely to receive these payments if you have received them in recent years. In addition, even if you will not be receiving hold harmless payments next year, the impact of the proposed rule may not be significant on your hospital if you do not treat many Medicare patients or do not have significant drug costs associated with Medicare patients. Given this, do you believe that these proposed cuts will have a significant impact on your hospital's reimbursement next year? Yes No I am not sure 3. Overall, how concerned is your hospital about the impact of the proposed 340B payment cut on your institution and its patients? We are VERY CONCERNED We are SOMEWHAT CONCERNED We are NOT CONCERNED 4. Please estimate what percent of your payer mix is devoted to patients who are self-pay or covered by Medicaid, Medicare, or other public programs. 5. Do you face difficulties accessing 340B pricing on non-retail drugs billed separately to Medicare Part B? Yes No I am not sure 4

5 General Questions & Demographics 6. How much does your hospital spend in one year to implement and remain in compliance with the 340B program (e.g., costs of split billing software, staffing, etc.)? Less than $100,000 $100,000 - $200,000 $200,001 - $300,000 $300,001 - $400,000 $400,001 -$500,000 $500,001 - $750,000 $750,001 - $1 Million More than $1 Million 5

6 Estimating Financial Impact Hospitals should determine the financial loss they would incur if Medicare finalized this payment cut to 340B hospitals as proposed so that they can gauge the impact of this proposal and share that information with CMS. Based on our conversations with hospitals, there are multiple ways to determine the financial impact. Below, we suggest two ways to estimate this financial impact. One relies on payment information and billing records, whereas the other relies on payer mix information. * 7. Please estimate the financial impact of the proposed rule for a one-year period. Feel free to use one of the methodologies below or any other methodology you may have to answer the question. Methodology 1: Estimating the Financial Impact Based on Payments Step 1: Review list of HCPCS codes for which payment would change under the proposed rule. We compiled these HCPCS codes from the full list included in Addendum B to the proposed rule. We limited the codes to those with a status indicator of K, identifying them as separately payable drugs without pass through status. Step 2: Run a report from the EMR billing system for non-retail outpatient drug charges billed under OPPS on a hospital claim form to determine the number of units billed for each of these HCPCS codes that would be affected by the proposed rule for a one-year period. Step 3: Multiply the proposed reimbursement amount associated with each HCPCS code by the total number of units billed to Medicare Part B under OPPS for each of those HCPCS codes. The reimbursement amount can be found in the list of affected HCPCS codes we have compiled under the Payment Rate column. The payment information also comes from Addendum B to the proposed rule. Step 4: Add total reimbursement received for each HCPCS code to yield total reimbursement for all HCPCS codes. Step 5: Multiply the total reimbursement calculated in Step 4 by "0.27" or 27% to yield the financial impact your hospital will see as a result of this proposed rule. (Note: 27% reflects how much of your total payment you would lose after the ASP percentage reduction, including 22.5% of ASP and the 6% of ASP add-on). Methodology 2: Estimating the Financial Impact Based on Payer Mix Step 1: Evaluate what percent of your outpatients are insured by Medicare (if possible, narrow to how many are insured by Part B). Step 2: Apply this percentage to your 340B savings that pertain to hospital outpatient areas (excluding contract pharmacies and retail pharmacies, if applicable) to determine the dollar amount of your 340B 6

7 savings that pertains to Medicare Part B patients. Step 3: Multiply the 340B savings figure calculated in Step 2 by "0.27" or 27% to yield the financial impact your hospital will see as a result of this proposed rule. (Note: 27% reflects how much of your total payment you would lose after the ASP reduction, including 22.5% of ASP and the 6% of ASP add-on). What is the financial impact your hospital would face under the proposed rule for a one-year period? Less than $100,000 $100,001 - $250,000 $250,001 - $500,000 $500,001 - $1,000,000 $1,000,001 - $2,000,000 $2,000,001 - $5,000,000 $5,000,001 - $10,000,000 $10,000,001 - $15,000,000 $15,000,001 - $20,000,000 More than $20,000,000 7

8 Putting the Financial Impact In Context 8. What percent of your hospital's 340B savings that pertain to hospital outpatient areas (excluding contract pharmacies and retail pharmacies) would you lose under the proposed rule? 9. If this policy were to be finalized in its proposed form, would your organization withdraw from the 340B program? Yes, we would withdraw from the 340B program. We would LIKELY withdraw from the 340B program. No, we would NOT withdraw from the 340B program. I am not sure. 10. How would the financial impact of the proposed rule affect your hospital's ability to treat low-income and/or rural patients? Please check all that apply. Reduce level of uncompensated care we are able to provide Reduce discounts given on drugs for low-income and/or rural patients Reduce discounts given on co-pays for low-income and/or rural patients Reduce overall patient care/quality outcomes Close outpatient pharmacy(ies) Close one or more of our clinics Affect our ability to provide current level of infusion services Affect our ability to provide clinical services Reduce staffing in the pharmacy Reduce current level of pharmacy services (e.g., medication therapy management, pain management) Reduce non-pharmacy related programs (e.g., patient outreach, education, therapy services, community health care programs) Other (please specify) 8

9 11. How would the impact on your institution change if the proposed payment cuts were adopted by Medicare Advantage plans as well as Medicare Part B? The financial impact would be significantly worse. The financial impact would be somewhat worse. The financial impact would be the same. I am not sure. 9

10 Assessing Operational Impact 12. For hospitals subject to the GPO prohibition (DSH, children's, cancer), is your Medicare Part B reimbursement for non-retail drugs purchased at non-340b, non-gpo prices (e.g., wholesale acquisition cost (WAC)) a significant share of your total Part B drug reimbursement? Yes No I am not sure My hospital is not subject to the GPO prohibition 13. For hospitals subject to the orphan drug exclusion (RRC, SCH, cancer), is your Medicare Part B reimbursement for orphan drugs (non-retail) a significant share of your total Part B drug reimbursement? Yes No I am not sure My hospital is not subject to the orphan drug exclusion 14. How problematic would it be to include a drug's actual acquisition cost in a new location on the Medicare claim form when billing Medicare Part B for a non-retail separately paid drug? Not problematic Somewhat problematic Very problematic I am not sure 10

11 Beneficiary Co-pays The following question relates to Medicare Part B beneficiary co-pays. CMS indicates that one of the reasons for proposing payment cuts to 340B hospitals is to lower drug costs for Medicare Part B beneficiaries by reducing their co-pays, which are 20% of the Medicare reimbursement amount. * 15. Does your hospital provide assistance to help low-income Part B beneficiaries afford their co-pays? Yes No I am not sure 11

12 Your thoughts 16. Please use the space below to share any specific concerns you may have regarding how this proposed rule would impact your hospital and its ability to treat low-income and/or rural patients. 12

13 Identifying Information We ask that you please provide answers to the questions below as it will help us in analyzing the survey results. Thank you! 17. What is your name? 18. What is your address? 19. What is the name of the hospital that you responded to this survey for? 20. What is the 340B ID or Medicare Provider Number (MPN) for the hospital that you responded to this survey for? 13

14 Thank You! Thank you for completing the survey! Your answers will be very helpful as we work to provide hospitals with guidance on this proposed Medicare OPPS rule and in crafting our own comments to CMS. Please ensure you click "DONE" below to save all your survey responses. Thank you! 14