CMS is focusing on drug payment policies—how will this manifest in 2019 rulemaking?

June 5th, 2018

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Note:  The following article synopsis was NOT provided by HCPro. It was created by Find-A-Code/innoviHealth.

Article Overview

This article reviews how CMS’s drug payment priorities may show up across 2019 rulemaking and related federal actions. It discusses the broader policy environment affecting hospitals and other providers, including transparency efforts, outpatient payment proposals, 340B-related changes, CAR-T payment considerations, and expected updates in major Medicare rulemaking vehicles. It is intended for hospital revenue cycle, HIM, coding, compliance, and reimbursement professionals who need to monitor CMS policy direction and comment opportunities.

Why This Topic Matters

The piece helps providers anticipate policy changes that could affect hospital payment, administrative burden, and public reporting expectations. It is especially relevant for organizations following CMS proposals that may alter how drugs and drug-related services are paid under Medicare.

Article Sections

  1. CMS drug payment policy priorities and the 2019 rulemaking landscape

    An overview of CMS’s attention to drug pricing and the main rulemaking and policy channels where providers may see related proposals.

  2. Provider feedback, RFI timing, and proposed rule comment strategy

    Discussion of how the agency is seeking input and why hospitals and other stakeholders are being encouraged to participate in multiple comment opportunities.

  3. Transparency, site neutrality, 340B, and packaging concerns

    A look at the broad policy themes that may affect payment levels, charge reporting, and administrative burden across hospital settings.

  4. CAR-T payment, coding, and coverage questions

    Coverage, reimbursement, and coding issues surrounding CAR-T and the ways CMS appears to be approaching this emerging therapy area.

  5. Looking ahead to OPPS rulemaking

    Expectations for outpatient policy changes in upcoming rulemaking, including potential shifts in reporting, payment structure, and other drug-related provisions.

What You Will Learn

  • How CMS’s drug payment priorities are shaping 2019 Medicare rulemaking
  • Which broad policy areas are drawing provider concern and comment
  • Why hospitals are monitoring transparency, site-neutrality, and 340B-related proposals
  • How emerging cell and gene therapy payment issues are entering the policy discussion
  • What kinds of outpatient rulemaking themes may continue into later CMS proposals

Who Should Read This

  • Hospital revenue cycle teams
  • Health information management professionals
  • Coding and reimbursement staff
  • Compliance professionals
  • Hospital administrators
  • Medicare policy analysts

Codes Discussed

  • HCPCS Level II: Q2040
  • HCPCS Level II: Q2041

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