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Advocacy News

NHIA Submits Comments on Proposed 2023 Physician Fee Schedule

August 30, 2022

NHIA submitted comments on a CMS proposed rule (CMS-1770-P) that would affect Medicare payments and coverage of COVID-19 vaccines and monoclonal antibodies (mAbs) and coding and billing requirements related to the use of single dose containers and drug waste. 

While NHIA applauds the continued coverage for pre-exposure prophylaxis to COVID-19 with monoclonal antibodies beyond the PHE, the association registered concerns that patients will not have access to mAbs in the home for treatment or post-exposure prophylaxis following the expiration of the emergency use authorization (EUA). NHIA believes this raises equity issues, particularly for Medicare beneficiaries in rural areas and for those without the means to travel to an infusion center. Continuous access to home infusion should be part of the agency’s future pandemic preparedness strategy.   

The association also noted that CMS’ proposal to require a separate modifier to be included on all claims for drugs with no discarded amounts would be administratively burdensome, cause confusion when a drug has more than one manufacturer (generic drugs), and may require substantial investments to update billing software systems. Instead of creating an entirely new, unnecessarily burdensome system, NHIA recommends that the Medicare Administrative Contractors (MACs) provide education regarding use of the JW modifier or limit its use to drugs identified for the rebate program.

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