On April 23, the Centers for Medicare & Medicaid (CMS) released the FY2020 Inpatient Prospective Payment System (IPPS) proposed rule. The IPPS rule addresses ways to improve payment for CAR-T therapies and is a step in the right direction. The American Society for Transplantation and Cellular Therapy (ASTCT) has been working closely with CMS to improve reimbursement for chimeric antigen receptor T-cell (CAR-T) therapy to assure appropriate patient access to this lifesaving therapy and will continue to work with the agency on this important issue.
ASTCT applauds CMS for being responsive to our concerns about CAR-T reimbursement by releasing some specific proposals and a request for comments on a number of additional ideas. Some of the issues outlined in the proposed rule reflect the concerns and proposals ASTCT has provided CMS over the past 18 months. While we are encouraged by the forward movement, ASTCT believes that the proposal does not go far enough to protect patient access and does not address the significant reimbursement inadequacies that make delivering these therapies to Medicare patients unsustainable for centers.
The agency proposed to increase the amount of the new technology add-on payment (NTAP) for all eligible services, including the two approved CARs, from 50 percent to 65 percent of the cost. Previously, ASTCT had recommended increasing the maximum NTAP to 80 percent, which still would not cover the full cost of CAR-T therapy but would provide much needed relief to providers. In what appears to be a response to an ASTCT recommendation from last year, CMS requests comments on eliminating the NTAP payment calculation for the two currently approved CAR-T products and replacing the calculation with a uniform payment in the amount of $242,500 (65% of the product cost). In addition, CMS is looking for input on developing a new MS-DRG and is interested in receiving feedback on creating alternative payment models for CAR-T. ASTCT is still examining these requests and will provide feedback to the agency.
ASTCT is pleased that CMS is engaged on the issue of improving reimbursement for current and future CAR-T therapies. We welcome the opportunity to continue to work with CMS to ensure these policy changes support the needs of patients. ASTCT is reviewing the proposed rule and appreciates the opportunity to respond with comments.