ASNC Submits Comments Letter Regarding Hospital Outpatient Prospective Payment System (HOPPS)

In July, the Centers for Medicare and Medicaid Services (CMS) published their 2013 proposed rules for the Medicare Physician Fee Schedule (MPFS) and the Hospital Outpatient Prospective Payment System (HOPPS). ASNC submitted a comments letter detailing the Association's feedback for the CMS. Key areas of interest to ASNC include the following:

  • Conversion of Medical Isotope Production from Non-Highly Enriched Uranium (HEU) Sources
  • Packaging of Diagnostic Radiopharmaceuticals
  • CMS Offset Policy:
  • Increase in the Threshold for Separate Payment for Biologicals, Drugs, and Therapeutic Pharmaceuticals
  • Average Sale Price of +6% in 2013
ASNC supports the Administration's desire to end U.S. reliance on foreign sources of highly enriched uranium (HEU) and to further production of domestic sources of non-HEU. However, the requirement that hospitals obtain 100 percent of isotopes from non HEU sources is concerning, as supply for these non-HEU isotopes is not likely to be able to keep up with demand.

Click Here for a PDF with the full text of the letter.