OPPS Comment Radiopharm Competitive Settings

 TOPIC: Payment for diagnostic radiopharmaceuticals.   

III.V.B.c. 89 Fed Reg 59213-9.

I support the separate billing of certain costly radiopharmaceuticals.  This supports the fact that OPPS is a prospective payment system sensitive to major levels (APCs for Radiology 1, 2, 3 etc).  This use of packaging plus levels is also found in DRGs as are MS-DRGs (w/MCC, etc).

CMS does not mention in this context incentives or perverse incentives regarding location of service.  Currently, diagnostic radiopharmaceuticals in Part B non-facility settings are paid separately (e.g. $600 scan, $2000 tracer).   This provides a current incentive to use these tracers only in part of the nuclear scan places of service, creating a segmented and therefore less competitive market.  By paying for costly tracers separately in both freestanding and facility outpatient settings, there will be a more level playing field and more potential for competition.

Thank you! Your comment has been submitted to Regulations.gov for review by the the Centers For Medicare & Medicaid Services.   Comment Tracking Number: m0s-l837-lcz4