AABB Billing and Reimbursement Initiatives
AABB is committed to seeking enhanced and fair reimbursement for blood products, and transfusion services and cellular therapies through both education regarding the complexities of blood coding and billing, and advocacy to reimbursement policy makers.
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AABB Billing Guide
Billing for Blood and Transfusion Services FAQ
Billing and Reimbursement for Stem Cell Processing Q & A
Reimbursement Advocacy
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NEW: Summary of 2010 Medicare Outpatient Payments for Blood Products and Stem Cell Processing
AABB has prepared a summary of the 2010 Medicare Hospital Outpatient Prospective Payment System rule, providing details about the payment rates blood products and cellular therapy services. The final rule — issued this month by the Centers for Medicare and Medicaid Services — calls for modest changes to payments for most blood products and bone marrow and stem cell processing services. However, payments continue to lag behind the actual costs of these products and services. Providers are urged to bill using the appropriate stem cell processing codes so that CMS can obtain better cost data to help determine payments for these services in the future. The new payment system takes effect Jan. 1, 2010.
AABB Comments on Medicare Proposed 2010 Outpatient Payments for Blood Products and Stem Cell Processing
In comments filed with the Centers for Medicare and Medicaid Services, AABB urged the agency not to implement proposed cuts in payments for many blood products. Instead, AABB recommended that CMS base the 2010 payment rates for blood products on the 2009 rates increased by the 3.1 percent change in the government-recognized blood and organ producer price index from July 2008 to July 2009. In separate joint comments, AABB, the American Society for Blood and Marrow Transplantation and the National Marrow Donor Program asked the agency not to implement its proposed change to classify allogeneic bone marrow/stem cell transplants as “inpatient only” procedures and therefore not pay for such services in an outpatient setting. A final hospital outpatient rule will be published this fall, with new payment rates taking effect January 1, 2010.
Medicare Proposed 2010 Outpatient Rule Would Cut Payments for Certain Blood Products and Only Modestly Increase Payments for Stem Cell Processing
AABB has prepared a summary of sections of the CY 2010 proposed rule for the Medicare Hospital Outpatient Prospective Payment System which pertain to payment rates for blood products and transfusion and cellular therapy services. The proposed rule — issued this month by the Centers for Medicare and Medicaid Services — calls for very small increases and in some instances modest decreases in payments for the most frequently transfused blood products (e.g., $188.92 for leukoreduced Red Blood Cells in 2010, versus $187.93 in 2009; and $468.66 for platelets, pheresis, versus $461.09 in 2009). However, the agency proposes significant decreases in the payments for some infrequently used blood products. Proposed payments for laboratory bone marrow/stem cell processing codes modestly increase, but still lag notably below the actual costs of these services. Comments on the proposed rule are due to CMS by August 31.
CMS Proposed Rule Would Reflect Hospital Blood Costs in Inpatient “Market Basket”
In its proposed rule for 2010 payments for hospital inpatient services, the Centers for Medicare and Medicaid Services (CMS) took the long-awaited step of proposing to use a new prospective payment index (PPI) that would specifically track changes in the cost of blood products to hospitals. For years, AABB, along with the American Red Cross, America’s Blood Centers and AdvaMed, has asked the agency to include such an index in calculating its overall inflationary adjustments to the “market basket” for inpatient services. Currently, in calculating price changes for blood and blood products for the hospital market basket CMS uses another PPI which has no relationship to blood costs. In comments to the agency, AABB, ARC, ABC and AdvaMed commend the agency for taking this important step. The proposed rule is expected to take effect on October 1, 2009.
CMS Clarifies MUE Policy
CMS has issued a letter clarifying a policy relating to Medically Unlikely Edits. In an April 14, 2009 letter, CMS states that "providers cannot utilize an Advanced Beneficiary Notice under any circumstance to bill a beneficiary for a [unit of service] denied due to an MUE even if the denial is upheld due to lack of medical necessity on appeal." CMS developed MUEs to reduce the paid claims error rate for Medicare Part B claims. An MUE for a HCPCS/CPT code is the maximum units of service that a provider would report under most circumstances for a single beneficiary on a single date of service. CMS automatically denies all units of service billed in excess of the CMS-determined criteria for the number of units. Excess charges beyond the MUE level may not be billed to the beneficiary. The majority of MUEs are posted on CMS' Web site.
Frequently Asked Questions and Answers Regarding Billing for Stem Cell Processing
AABB consulted experts to provide responses to frequently asked member questions regarding the billing and coding of stem cell processing, particularly in light of Medicare's recent recognition of certain stem cell processing codes. Although providers are always advised to consult individuals at their institutions who are responsible for coding and billing as well as the Medicare contractors for their geographical locations to determine correct coding and billing, these FAQs provide helpful information.
Archived News
AABB Billing Guide
AABB’s Billing Guide is intended to assist hospitals, clinicians, billing and coding professionals involved with the utilization and subsequent billing of the services and procedures associated with the use of blood and transfusion and cellular therapies. AABB produced this guide with the generous support and cooperation of the blood sector member companies of the Advanced Medical Technology Association (AdvaMed).
The Billing Guide provides updated information and references for Medicare policies and guidance relating to blood. Throughout the Billing Guide, all coding systems – including revenue codes, CPT, HCPCS, and ICD-9-CM – have been updated to reflect the most recent changes.
In addition, this revised Billing Guide provides updated information on appropriate coding and billing for hematopoietic progenitor cell collection and processing, including information regarding Medicare’s recent proposal to recognize certain stem cell processing codes for the first time (see Section VIII). The Billing Guide also contains information regarding billing and coding for the following additional products and services:
- Apheresis – Section VIII
- Blood Derivatives – Section VI
- Tissue and Bone – Section VI
Many U.S. hospitals do not bill accurately, or at all, for blood transfused in the inpatient setting. Failure to bill appropriately for blood can hinder patient access to new technologies and potentially can affect the hospital’s bottom line. The Billing Guide is intended to help hospitals bill accurately and completely for blood products and services. Though AABB does not provide any guarantees of reimbursement, the intent of this publication is to assist hospitals in understanding the billing rules and procedures that apply for Medicare and other payers.
The AABB Billing Guide is available below in PDF format for viewing and printing:
AABB Billing Guide – Version 4.0 (PDF)
AABB will post periodic updates to this guide in this section as Medicare or other reimbursement and coding policies relating to blood are revised. Please check this page periodically for updates.
Reimbursement Advocacy
AABB serves as a leading advocate before the Centers for Medicare and Medicaid Services (CMS) and Congress regarding the need for fair and timely Medicare reimbursement for blood products and services and cellular therapies. In the inpatient arena, AABB, along with others in the blood community, has supported efforts to allow Medicare to better account for the increasing cost of blood. In particular, AABB asked Congress and CMS to create a new blood-related producer price index (PPI) to be used in calculating the change in prices for goods and services hospitals use to provide inpatient care (the so-called "market basket"). In recent years, the cost of blood had been inappropriately bundled in unrelated indices for "chemicals" or ”miscellaneous goods.” In response, the Bureau of Labor Statistics is currently collecting data from blood centers to establish a separate PPI for blood and organ banks. AABB and its fellow blood organizations will continue to work to ensure that CMS adopts the new blood PPI and that this index does, in fact, reflect changes in blood costs as accurately as possible.
In the realm of outpatient reimbursement, AABB was a staunch advocate for separate ambulatory payment classifications (APCs) for individual blood products and services when CMS first established the APC outpatient prospective payment system in 1998. AABB continues to support improvements in the APC system to ensure it accurately accounts for the costs of blood and reflects the increasingly complex array of blood products and services. Specifically, AABB has urged CMS to use outside cost data provided by hospitals and blood centers to establish its outpatient payment rates for blood products, rather than continuing to rely on faulty CMS data.
In response to AABB’s requests, CMS issued revised guidance regarding billing for blood under the hospital outpatient prospective payment system, which took effect July 2005. This guidance can be found at http://new.cms.hhs.gov/transmittals/downloads/R496CP.PDF. AABB, along with others in the blood banking community, continue to urge CMS to further update and improve its guidance regarding blood-related reimbursement.
AABB also is a strong advocate for improved Medicare reimbursement for bone marrow, hematopoietic progenitor cells and apheresis-related procedures. AABB, along with other interested organizations, have urged CMS to adjust its payments to hospitals for laboratory processing services associated with bone marrow and peripheral blood progenitor cell transplants to reflect their actual costs.
Finally, AABB has championed new or improved Current Procedural Terminology (CPT) codes for transfusion medicine and cellular therapy-related procedures. For example, in response to requests from AABB, the American Medical Association in 2005 issued new CPT codes for a pretransfusion electronic crossmatch test (86923) and for volume reduction of blood products (86960).
Free Monthly Email Updates
AABB is developing a national contact list of interested parties who wish to receive the latest information on billing and reimbursement for blood products, transfusion services and cellular therapies. Interested parties will receive free monthly updates on revised Medicare policies and appropriate coding for blood and transfusion therapies. This information will assist facilities in dealing with the complexities and changes in reimbursement policies. Interested parties will receive information about audioconferences and other educational forums focusing on billing and reimbursement. In addition, email recipients will receive answers to frequently asked billing questions.
If you are interested in receiving these monthly updates, please sign up here.
If you have questions relating to billing and reimbursement for blood products and services, please contact govt&legal@aabb.org.
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