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BIO Submits Comments Re: Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems (OPPS) and Quality Reporting Programs Proposed Rule

October 21, 2019

Dear Administrator Verma,

The Biotechnology Innovation Organization (BIO) appreciates the opportunity to comment on
the Centers for Medicare & Medicaid Services’ (CMS’) Medicare Hospital Outpatient
Prospective Payment and Ambulatory Surgical Center Payment Systems Proposed Rule.

BIO is the world's largest trade association representing biotechnology companies, academic
institutions, state biotechnology centers and related organizations across the United States
and in more than 30 other nations. BIO’s members develop medical products and
technologies to treat patients afflicted with serious diseases, to delay the onset of these
diseases, or to prevent them in the first place. In that way, our members’ novel
therapeutics, vaccines, and diagnostics not only have improved health outcomes, but also
have reduced healthcare expenditures due to fewer physician office visits, hospitalizations,
and surgical interventions. BIO membership includes biologics and vaccine manufacturers
and developers who have worked closely with stakeholders across the spectrum, including
the public health and advocacy communities, to support policies that help ensure access to
innovative and life-saving medicines and vaccines for all individuals.

BIO represents an industry that is devoted to discovering new treatments and ensuring
patient access to them. Accordingly, we closely monitor changes to Medicare’s
reimbursement rates and payment policies for their potential impact on innovation and
patient access to drugs and biologicals. Our comments on the Proposed Rule are outlined

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