Statement of the problem.The Medicare Prescription Drug, Improvement, and Modernization Act (MMA) mandates that the Department of Health and Human Services (HHS) recommend a strategy to incorporate separately drugs billable the most expensive being erythropoiesis-stimulating agents (ESAs) to treat anemia dialysis-related into the composite rate for end-stage renal disease (ESRD). Congress has directed the Centers for Medicare and Medicaid Services (CMS) to use historical archived data to assess an equitable payment for ESAs. Given its documented overuse and recent allegations of "gaming" in preparation for future ESA bundling, we feel that the CMS approach is problematic. We encourage Health Affairs readers to enter into a discussion regarding alternative evidence-based approaches, especially those that incorporate clinical criteria, to determining a fair and equitable method of bundling ESAs.
full paper can be accessed at:
http://healthaffairs.org/blog/2008/09/23/epoetin-payment-focus-on-clinical-benefit/#more-443