August 29, 2014
BY ELECTRONIC DELIVERY
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Hubert H. Humphrey Building
200 Independence Avenue, S.W.
Washington, D.C. 20201
Re: Medicare and Medicaid Programs: Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs; Physician-Owned Hospitals: Data Sources for Expansion Exception; Physician Certification of Inpatient Hospital Services; Medicare Advantage Organizations and Part D Sponsors: Appeals Process for Overpayments Associated With Submitted Data [CMS-1613-P]
Dear Administrator Tavenner:
The Biotechnology Industry Organization (BIO) is pleased to comment on the Centers for Medicare & Medicaid Services (CMS) proposed rule regarding payment policies under the calendar year (CY) 2015 hospital outpatient prospective payment system (OPPS), published in the Federal Register on July 14, 2014 (the “Proposed Rule”).1 BIO represents more than 1,000 biotechnology companies, state biotechnology centers, academic institutions, and related organizations both in the United States and abroad. BIO members are critical contributors to the research and development of innovative health care, agricultural, industrial, and environmental biotechnology products.