BIO Comments on the CY 2014 Physician Fee Schedule Proposed Rule

September 6, 2013




Marilyn Tavenner


Centers for Medicare & Medicaid Services

Department of Health and Human Services

Room 445-G

Hubert H. Humphrey Building

200 Independence Avenue, S.W.

Washington, D.C. 20201


Re:  Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule, Clinical Laboratory Fee Schedule & Other Revisions to Part B for CY 2014 [CMS-1600-P]


Dear Administrator Tavenner:


          The Biotechnology Industry Organization (BIO) appreciates this opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS) proposed rule regarding payment policies under the physician fee schedule (PFS), clinical laboratory fee schedule, and other revisions to Part B for calendar year (CY) 2014 (the “Proposed Rule”). BIO represents more than 1,100 biotechnology companies, academic institutions, state biotechnology centers, and related organizations in the United States.  BIO members are involved in the research and development of health care, agricultural, industrial, and environmental biotechnology products.


          BIO represents an industry that is devoted to discovering new treatments and ensuring patient access to them.  Accordingly, we continue to monitor changes to Medicare’s reimbursement rates and payment policies for their potential impact on innovation and patient access to drugs and biologicals.  Toward this end, BIO is greatly concerned that physicians once again face a substantial, negative update to the conversion factor.  The estimated cut of 24.4 percent in physician payment rates, in addition to payment reductions due to sequestration, simply cannot be implemented without dire consequences to patient care.  We agree with CMS that a long-term solution to avert future negative updates is critical, and we urge CMS to work with Congress to reform the methodology.  Until such reform is enacted, CMS should do anything in its power to mitigate these cuts and ensure that Medicare beneficiaries continue to have access to high quality care in 2014 and beyond.

Click here to see the full comment letter (PDF).