Educational Resources: IVIG

Medicare IVIG Access Act

I. Medicare Payment to Physicians & Hospital Outpatient Departments

1. Review & Collect Data
1. Secretary is required to review available data, such as OIG, ASPE and patient, physician and pharmacist surveys; and
2. collect data on differences between payments to providers and their costs for acquiring IVIG.
2. Update Payment to Recognize Unique Nature of IVIG
   Following the precedent of the MMA 2003 provision to determine payment for hemophilia clotting factor, the Secretary is required to provide, if appropriate, a payment in addition to ASP+__% for “all items and services related to the furnishing of IVIG, in an amount that the Secretary determines to be appropriate.” The legislation does not tell the Secretary what amount to pay. Rather, it provides authority to pay an additional amount based on data demonstrating the difference between cost and Medicare payment.
3. Maintain Pre-Administration Fee
   CMS should not further disrupt access to IVIG by eliminating the pre-administration fee they temporarily established in 2006. Rather, as the House of Representatives stated last year, the pre-administration fee should be continued until the Secretary either determines the payment to be adequate or implements a new payment policy.

II. Medicare PIDD Home Infusion Benefit

1. Makes the current PIDD home infusion benefit whole. The bill deletes the prohibition on covering “items or services related to the administration” of IVIG and requires the Secretary to review data on the appropriateness of IVIG home infusion and calculate the amount that should be paid to a provider furnishing IVIG in the home to PIDD patients.
2. Protects Medicare beneficiaries receiving home infusion benefits by clarifying that entities providing home infusion are able to conduct criminal background checks of employees who will have direct contact with Medicare beneficiaries in the home.

III. Patient Access & Quality of Care Surveys
Requires CMS to contract with an eligible organization or entity to conduct 2 surveys within three years to measure changes in patient access to IVIG and changes in health care status.