EPO and recent Medicare changes

Since Medicare made recent changes in regulations as regards timing of Hgb measurement and adjustment/dispensing of EPO, I would like to ask how dialysis clinics are adapting policy in response. Do the patients have lab draw near the end of the month and obtain adjusted dose at the beginning of the following month? Does the clinic provide the EPO or is an outside pharmacy used? If the clinic provides, is the EPO pharmacy dispensed then handed to the patient? Does the clinic pay the pharmacy? Does the patient get a prescription and obtain and pay for the EPO through their own pharmacy? The logistics of providing and paying for EPO are becoming a nightmare. I am trying to find a workable solution.

Most clinics buy EPO from a supplier. Large corporations get better prices for EPO than individual clinics. This is why some independent clinics have banded together into a buying group to get better prices. The National Renal Administrators Association has formed one of those buying groups

Medicare reimburses clinics for EPO for in-center and home patients. Here’s the Medicare EPO monitoring policy:

A normal pharmacy cannot bill Medicare for EPO because EPO is a Medicare Part B covered drug. The pharmacy must be a Medicare provider pharmacy and it must bill the Medicare durable medical equipment regional carrier (the insurance company that pays the bills for Part B drugs in the region). The new Medicare Part D is not supposed to cover EPO for people on with kidney damage or kidney failure because it is Part B covered and Part D won’t cover Part B covered drugs.

i do labs once a month unless the results call for repeat testing, if really low h/h or high h/h i will repeat and adjust dose. we provide epo to our pts.