I recently represented the sterile compounding pharmacy industry at the Alliance for Patient Access (AfPA) Policy Forum on this issue. My sincere appreciation goes out to the AfPA for planning and executing the meeting and to Drs. David Kloth (Connecticut Pain Care) and Joshua Prager (Center for Rehabilitation of Pain Syndromes and California Pain Medicine Centers) for their leadership on this issue.

Over the course of the two-day forum, leading physicians in pain management and Medicare policy experts (who are also schooled in the detail and history of payment and coverage regulation), discussed the merits of taking a legislative path and negotiating through the coverage, coding and payment web.

Attorneys Paul Radensky and Paul Rudolf of the Arnold & Porter Washington, D.C. office are working with the group in three key areas: drug payment, administrative hassles, and pump refill and electronic analysis/programming code valuation.

The current objectives are:

Drug payment: Seek the development of a fee schedule to replace invoice-based pricing with fair payment to reflect costs for acquiring, handling and maintaining drugs. Pursuing regional fee schedules is a near-term objective under consideration, while longer-term, seeking CMS adoption of a national method for a fee schedule is being examined by the group.

Administrative hassles: Address significant cost and time issues with regional MACs handling the claims.

Pump refill and electronic analysis/programming code valuation: Look at the distribution for these codes and model indirect/direct ratios and practice cost indices and the impact of different specialty mixes. Radensky and Rudolf also are working to confirm current specialty crosswalk for these services with CMS. In addition, they are investigating the status and scope of the AMA’s survey of interventional pain indirect expense and considering the impact on the timing and scope of pursuing the issue with CMS. This will be useful in considering whether new codes may be required.