On November 1, 2007, the Centers for Medicare and Medicaid Services (CMS) published the final Hospital Outpatient Prospective Payment System (HOPPS) rule for 2008. The rule includes modest payment increases for most blood products and more significant changes in the way CMS pays for stem cell processing.

Bone Marrow and Stem Cell Processing

After several years of effort on the part of AABB, the American Society for Hematology (ASH), and others, CMS will recognize the bone marrow/stem cell laboratory processing codes.  In addition, payments for these services have increased substantially from the levels published in the proposed rule (see attached Table 1).  These codes are:

38207    Cryopreserve stem cells

38208    Thaw preserved stem cells

38209    Wash harvest stem cells

38210    T-cell depletion of harvest

38211    Tumor cell deplete of harvest

38212    Rbc depletion of harvest

38213    Platelet deplete of harvest

38214    Volume deplete of harvest

38215    Harvest stem cell concentrate

CPT Codes 38207-38209, which represent freezing, storing and thawing bone marrow/stem cells prior to transplant, have been assigned to APC 0110 with a payment of $216.   Although AABB believes this payment is significantly lower than actual costs, it is notably greater than the $52.00 payment CMS initially proposed for these services.

CMS will also pay more for CPT Codes 38210-38215, which represent various bone marrow/stem cell depletion codes, than originally proposed.  These codes now have been assigned to APC 393, paying $362.55.

AABB had also requested that the T-cell and tumor cell depletion codes (38210 and 38211) be placed in a separate higher paying APC and provided survey data to demonstrate the costs of these services.  In the discussion of this issue in the final rule CMS explained that it assigned all of the depletion codes to a single APC because there were no actual claims data for these services.  CMS plans to revisit the APC placement for the individual codes once claims data become available.  It is critical that providers bill using the new bone marrow and stem cell processing codes so that CMS can obtain accurate cost-data to adjust payments in future years.

Payments for Blood Products

As reflected in Table 2, the final payment rates for 19 of the 34 blood and blood product APCs will be increasing in 2008.  The 19 APCs increasing in payment are generally the higher volume products, which CMS estimates represent 77 percent of the total units billed to Medicare. For 2008, CMS will continue to use a special methodology to set payment rates for blood products at the unadjusted median cost calculated using a specific simulated blood cost-to-charge ratio for each hospital that does not have a blood cost center.

Blood Transfusions

CMS will continue its current policy requiring a single unit of CPT code 36430 (Transfusion, blood or blood components) to be reported regardless of how many transfusions occur on a single date of service.  (The blood product itself is paid based on the actual number of units provided.) The APC Advisory Committee had recommended to CMS at its March 2007 meeting that CMS identify when multiple units of blood or blood components are transfused and to trigger an additional discounted payment for the second and subsequent blood administration services on a single date of service. In the rule, CMS rejects the Advisory Committee recommendation, but reminds hospitals that in billing code 36430, hospitals should include charges for the totality of all transfusion services provided on a single date of service.

Payment for Part B Drugs and Blood Clotting Factors

CMS will reduce the payment for drugs paid for under HOPPS from 106 to 105 percent of Average Sales Price (ASP).  In reviewing actual cost data on separately paid drugs, including blood clotting factor, CMS found that at the rate of ASP + 6 percent hospitals were being overpaid. For 2008, CMS will be reducing the payment rate to ASP + 5 percent.  Further reductions are likely in future years perhaps to the level of ASP +3 percent, which CMS feels is justified based on current cost data.

Clotting Factor - CMS will be increasing the administration fee for furnishing blood clotting factor by 4 percent to $0.158 per unit.  

IVIG - CMS is continuing to pay for IVIG preadmission services (G0332) at a rate of $37.71 for 2008. CMS indicates it will consider the continued need for separate payment for IVIG preadmission services for 2009, including the possibility of packaging this service in the future.

Update and Hospital Impact

For 2008, the overall inflationary update in the outpatient payment rates will be 3.3 percent.  Due to other policy changes being made by the rule the average increase in outpatient payments for hospitals will be 3.8 percent, with urban hospitals seeing a slightly larger increase than rural hospitals.  Teaching hospitals will see an average increase of about 3.8 percent.

2008 Hospital Outpatient Prospective Payment System (HOPPS) Regulations (CMS-1392-FC)

Table 1, Procedural Codes