ACCC Submits Comments to CMS on HOPPS Final Rule

  ACCC's Drug Database and Compendia-Based Drug Bulletin Put on Hold

  FDA Approves New Indication for Gleevec

  FDA Approves Genzyme's Mozobil

  ACCC's 4th Annual Hospital Summit Highlights Trends in Cancer Care

  ACCC Final Rule Analysis Conference Call Available on Website

  CMS Clarifies Requirements for Physician Supervision of HOPD Therapeutic Services

  ACCC Analysis: Final 2009 OPPS Rule, Payment for Some Chemo Administration Services Increases, Others Decline

  ACCC Analysis: Medicare Physician Fee Schedule Final Rule for 2009, Payments for Drug Administration Services Reduced

  CMS Postpones RAC Program

  ACCC's Drug Bulletin on Hold Until 2009

  FDA Approves Treanda to Treat Patients with Relapsed Indolent Non-Hodgkin's Lymphoma

  CMS Releases Final 2009 Hospital Outpatient Department Rule, ASP +4 Percent

  CMS Releases Final 2009 Changes to Payment Policies and Rates Under Medicare Physician Fee Schedule

  CMS Releases Guidance on Use of Drug Compendia

Pharmacy Service and Chemotherapy Administration Costs in the Cancer Outpatient Hospital Setting

In the hospital setting, an AWP minus 5 percent payment from Medicare is current reimbursement for the drug, chemotherapy administration, and, in many cases, for the pharmacy service costs a hospital incurs in providing cancer care. The Association of Community Cancer Centers (ACCC) believes the Medicare program should recognize and reimburse for pharmacy service costs as Congress shifts to an AWP or other drug payment that will reimburse only for the cost of the drug.

Examples of these pharmacy service and chemotherapy administration costs are provided below. The pharmacy service costs are not billed by many hospitals to chemotherapy administration, but rather, to the drug AWP payment they receive.

Pharmacy Service Costs:

  1. Pharmacists, often certified in oncology, serve an important safety function: they are able to consult with doctors so that the clinical side as well as the drug interaction/contraindications and dosing side of the equation can be considered for each patient before chemotherapy is given. This consultation often results in a different methodology for mixing or giving the drugs. For example, some drugs may be given sequentially instead of through the same drip bag so as not to inactivate the drug in a certain patient who might also be taking other drugs.
  2. Nurses often ask pharmacists to consult with patients about their immediate and any ongoing reactions they may have to cytotoxic drugs.
  3. Hospitals incur costs to maintain an inventory of expensive cancer drugs. Pharmacists must also spend time taking inventory and replacing drugs as the drug’s shelf-life expires.
  4. Chemotherapy drugs come in individual vials that must be reconstituted, dissolved, and mixed under hoods under strict OSHA guidelines. They must then be drawn into an IV or be added to other fluids. Each time this is done, drugs must be labeled, recorded, and tracked for safety purposes.
  5. There are ongoing costs for maintaining the sterility of the hood under which these cytotoxic drugs are mixed, and to ensure there are no bacterial contaminants in the drugs. This requires random sampling of drugs as well as the development of specific order forms for chemotherapy drugs.
  6. Drug spillage, contamination, and spoilage are additional pharmacy service costs.
  7. Pharmacists also spend time setting up and reviewing protocols for their hospitals. Pharmacists then “build rules” into their computer systems so that certain drugs or interactions can be flagged when a doctor or technician is prescribing medications. This is an important safety function that changes as new drugs or research becomes available.
  8. If drugs are mixed but not administered to the patient because his white blood cell count is too low that day, those drugs are a pharmacy service cost.

Chemotherapy Administration Costs:

  1. Nursing personnel responsibilities in an infusion center include administering the drugs, monitoring and assessing the patients throughout their infusion, stabilizing patients during an emergency, chart documentation, educating patients on toxicity, side effects, and benefits of particular treatments, as well as follow up calls with patients.
  2. Equipment for the infusion center including such things as infusion chairs, beds, and pumps.
  3. The costs of keeping a sterile environment.
  4. The physical space of an infusion center must have several elements, including private space for contagious patients and immune-suppressed patients, space for family, a kitchen area and extra wiring, plumbing and bathrooms.
  5. The supplies used during a chemotherapy administration include tubing, needles, filters, syringes, band aides, and sterile gloves.
  6. Other supplies and equipment needed on-site include a crash cart, chart forms, computers, snacks, and nutritional supplements.

 

 

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Tuesday, January 06, 2009

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Last updated:1/6/2009