Cures Act imposes ASP model for infusion drugs

In bad-good scenario, bill will also finally pave way to reimbursement for services
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Friday, December 9, 2016

WASHINGTON – While the broader HME industry is cheering the passage of the 21st Century Cures Act, home infusion is facing reimbursement cuts—effective almost immediately.

The bill, on its way to the president for his signature, contains a provision that would shift payments for Part B home infusion drugs from an average wholesale price model to an average sales price model on Jan. 1.

“The inclusion of the ASP model is not new, but what may be more startling is it’s supposed to be implemented in less than 30 days,” said Tyler Wilson, president and CEO of the National Home Infusion Association. “There’s the cut in reimbursement (associated with the ASP model) and the fact that people don’t have time to remodel their businesses or do any budget planning.”

The ASP language was actually built in to the Cures Act to help “pay for” key elements of the Medicare Home Infusion Site of Care Act, which were also included in the bill. Medicare will now have to pay for services associated with providing Part B home infusion drugs, but not until 2021.

“We appreciate the services payment, but we never anticipated ASP would be imposed at one point, and then, any kind of services payment would come several years down the road,” said Wilson. “We’ve got to narrow this gap between the ASP and reimbursement. We’re working with lawmakers who are keenly aware of this problem.”

The notion of using an ASP model for infusion drugs is not new. The Office of Inspector General has issued at least three reports in the last few years recommending the change because it believed that paying for the drugs under an AWP model could create access issues or lead to excessive billing, something infusion stakeholders dispute.

Realistically, stakeholders say, CMS won’t be able to make such a dramatic shift in so short a time, especially with the holidays looming.

“We are looking at, what are the hurdles of implementing this, not just time-wise, but are there regulatory structures that we need to look at?” said Ken van Pool, vice president of legislative affairs for NHIA. “When you make a dramatic shift, it has to trickle down to CMS and the DME MACs and they have to start reacting.”