ASGCT Submits Comments to CMS on OPPS Proposal

In response to the Outpatient Prospective Payment System (OPPS) proposed rule, ASGCT indicated its support for removal of patient care services from the CAR T-cell therapy Q codes for tisangenlecleucel and axicabtagene ciloleucel to more accurately report, and to obtain more sufficient reimbursement for, administration of these therapies. The Society also supported the provision of payment for new Category III CPT codes as recommended by the Advisory Panel on Hospital Outpatient Payment, to allow for accurate reporting and the establishment of payment rates for CAR T-cell therapies beginning in 2019.

In addition, ASGCT stated that CAR T-cell therapies should be excluded from the biological classes being considered for a competitive acquisition program (CAP) for Part B Drugs and Biologicals. A CAP model would utilize vendors to attempt to negotiate discounts for Medicare.

This program has been utilized in the past without resulting in cost savings. Moreover, the autologous nature of CAR T-cell therapies make them poor candidates for such a program, since they cannot be provided in bulk prior to administration, and the low volumes of usage for the currently limited number of products would challenge the potential for cost savings.

ASGCT is also concerned that the introduction of an external vendor could create shipping delays and/or complications to chain of custody for this time-sensitive biological product. Significantly, this proposal would not solve the issue of insufficient Medicare reimbursement to providers for CAR T-cell therapy when provided on an inpatient basis.

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