CMS Publishes 2009 Hospital Outpatient Prospective Payment System Rule
The Centers for Medicare and Medicaid Services (CMS) has published its final Hospital Outpatient Prospective Payment System (HOPPS) rule for 2009. The rule, which can be found at http://edocket.access.gpo.gov/2008/E8-26212.htm, includes modest payment increases for most blood products and more significant changes in the way CMS pays for stem cell processing and apheresis-related procedures.
Payments for Blood Products
As reflected in Table 1, the final payment rates for most blood products will increase modestly. The most frequently billed blood codes will generally see increases in the 2-5 percent range. This includes red blood cells leukocyte-reduced, RBCs, platelet pheresis leukocyte-reduced, and RBC leukocyte-reduced, irradiated. However, as in prior years, the payments for very low volume blood codes will experience significant swings in payment.
|
Table 1
Blood Products |
|
CPT/ HCPCS |
Description |
2009 Final APC |
2008 Final Payment Rate |
2009 Final Payment Rate |
$Change |
%Change |
|
P9010 |
Whole blood for transfusion |
0950 |
$254.85 |
$230.40 |
-$24.45 |
-9.59% |
|
P9011 |
Blood split unit |
0967 |
$149.10 |
$31.12 |
-$117.98 |
-79.13% |
|
P9012 |
Cryoprecipitate each unit |
0952 |
$41.24 |
$42.46 |
$1.22 |
2.96% |
|
P9016 |
RBC leukocytes reduced |
0954 |
$185.15 |
$188.92 |
$3.77 |
2.04% |
|
P9017 |
Plasma 1 donor frz w/in 8 hr |
9508 |
$67.03 |
$76.73 |
$9.70 |
14.47% |
|
P9019 |
Platelets, each unit |
0957 |
$69.50 |
$73.25 |
$3.75 |
5.40% |
|
P9020 |
Plaelet rich plasma unit |
0958 |
$363.50 |
$394.95 |
$31.45 |
8.65% |
|
P9021 |
Red blood cells unit |
0959 |
$129.66 |
$136.82 |
$7.16 |
5.52% |
|
P9022 |
Washed red blood cells unit |
0960 |
$277.03 |
$261.64 |
-$15.39 |
-5.56% |
|
P9023 |
Frozen plasma, pooled, sd |
0949 |
$73.87 |
$58.83 |
-$15.04 |
-20.36% |
|
P9031 |
Platelets leukocytes reduced |
1013 |
$107.51 |
$111.67 |
$4.16 |
3.87% |
|
P9032 |
Platelets, irradiated |
9500 |
$121.72 |
$164.42 |
$42.70 |
35.08% |
|
P9033 |
Platelets leukoreduced irrad |
0968 |
$139.94 |
$128.19 |
-$11.75 |
-8.40% |
|
P9034 |
Platelets, pheresis |
9507 |
$441.03 |
$468.66 |
$27.63 |
6.26% |
|
P9035 |
Platelet pheres leukoreduced |
9501 |
$499.53 |
$514.82 |
$15.29 |
3.06% |
|
P9036 |
Platelet pheresis irradiated |
9502 |
$417.71 |
$469.53 |
$51.82 |
12.41% |
|
P9037 |
Plate pheres leukoredu irrad |
1019 |
$630.08 |
$653.50 |
$23.42 |
3.72% |
|
P9038 |
RBC irradiated |
9505 |
$195.18 |
$250.69 |
$55.51 |
28.44% |
|
P9039 |
RBC deglycerolized |
9504 |
$347.23 |
$341.43 |
-$5.80 |
-1.67% |
|
P9040 |
RBC leukoreduced irradiated |
0969 |
$240.27 |
$251.33 |
$11.06 |
4.60% |
|
P9043 |
Plasma protein fract,5%,50ml |
0956 |
$93.88 |
$15.62 |
-$78.26 |
-83.36% |
|
P9044 |
Cryoprecipitatereducedplasma |
1009 |
$83.69 |
$85.16 |
$1.47 |
1.76% |
|
P9048 |
Plasmaprotein fract,5%,250ml |
0966 |
$215.23 |
$196.27 |
-$18.96 |
-8.81% |
|
P9050 |
Granulocytes, pheresis unit |
9506 |
$1,387.55 |
$1,669.99 |
$282.44 |
20.36% |
|
P9051 |
Blood, l/r, cmv-neg |
1010 |
$147.90 |
$144.13 |
-$3.77 |
-2.55% |
|
P9052 |
Platelets, hla-m, l/r, unit |
1011 |
$645.94 |
$711.89 |
$65.95 |
10.21% |
|
P9053 |
Plt, pher, l/r cmv-neg, irr |
1020 |
$686.54 |
$649.24 |
-$37.30 |
-5.43% |
|
P9054 |
Blood, l/r, froz/degly/wash |
1016 |
$218.81 |
$101.68 |
-$117.13 |
-53.53% |
|
P9055 |
Plt, aph/pher, l/r, cmv-neg |
1017 |
$488.74 |
$480.41 |
-$8.33 |
-1.70% |
|
P9056 |
Blood, l/r, irradiated |
1018 |
$147.13 |
$226.31 |
$79.18 |
53.82% |
|
P9057 |
RBC, frz/deg/wsh, l/r, irrad |
1021 |
$373.99 |
$424.67 |
$50.68 |
13.55% |
|
P9058 |
RBC, l/r, cmv-neg, irrad |
1022 |
$263.46 |
$301.43 |
$37.97 |
14.41% |
|
P9059 |
Plasma, frz between 8-24hour |
0955 |
$77.93 |
$75.62 |
-$2.31 |
-2.96% |
|
P9060 |
Fr frz plasma donor retested |
9503 |
$52.64 |
$64.25 |
$11.61 |
22.06% |
Procedural Payments
Payments for most procedural codes will see modest increases in the 2-4 percent range. However, bone marrow/stem cell processing codes 38210-38215 will increase by more than 10 percent. Although these payment increases are higher than the 2-4 percent increases for most other procedural codes, they remain far below the actual cost of most stem cell processing procedures. AABB and other interested parties will continue to advocate for increases in these payments in future rulemakings. At the same time, it is important that hospitals review their chargemasters to assure they are accurately accounting for the costs associated with these procedures since CMS will base future payments on these cost data.
The flow cytometry codes (technical component) will experience an increase over 8 percent in 2009 while the codes for reading flow cytometry vary substantially. For example, the payment for reading 2-8 slides goes down 34 percent while the payment for reading 9-15 slides goes up 126 percent. The G code for a bone marrow aspirate, through the same incision as a bone marrow biopsy, will experience a large decrease.
Table 2 lists the final payments for transfusion and stem cell processing codes.
|
Table 2
Procedural Codes |
|
CPT/ HCPCS |
Description |
2009 Final APC |
2008 Final Payment Rate |
2009 Final Payment Rate |
$Change |
%Change |
|
36430 |
Blood transfusion service |
0110 |
$216.35 |
$221.59 |
$5.24 |
2.42% |
|
36440 |
Bl push transfuse, 2 yr or < |
0110 |
$216.35 |
$221.59 |
$5.24 |
2.42% |
|
36450 |
Bl exchange/transfuse, nb |
0110 |
$216.35 |
$221.59 |
$5.24 |
2.42% |
|
36455 |
Bl exchange/transfuse non-nb |
0110 |
$216.35 |
$221.59 |
$5.24 |
2.42% |
|
36511 |
Apheresis wbc |
0111 |
$732.85 |
$759.70 |
$26.85 |
3.66% |
|
36512 |
Apheresis rbc |
0111 |
$732.85 |
$759.70 |
$26.85 |
3.66% |
|
36513 |
Apheresis platelets |
0111 |
$732.85 |
$759.70 |
$26.85 |
3.66% |
|
36514 |
Apheresis plasma |
0111 |
$732.85 |
$759.70 |
$26.85 |
3.66% |
|
36515 |
Apheresis, adsorp/reinfuse |
0112 |
$1,949.26 |
$2,033.73 |
$84.47 |
4.33% |
|
36516 |
Apheresis, selective |
0112 |
$1,949.26 |
$2,033.73 |
$84.47 |
4.33% |
|
36522 |
Photopheresis |
0112 |
$1,949.26 |
$2,033.73 |
$84.47 |
4.33% |
|
38205 |
Harvest allogenic stem cells |
0111 |
$732.85 |
$759.70 |
$26.85 |
3.66% |
|
38206 |
Harvest auto stem cells |
0111 |
$732.85 |
$759.70 |
$26.85 |
3.66% |
|
38207 |
Cryopreserve stem cells |
0110 |
$216.35 |
$221.59 |
$5.24 |
2.42% |
|
38208 |
Thaw preserved stem cells |
0110 |
$216.35 |
$221.59 |
$5.24 |
2.42% |
|
38209 |
Wash harvest stem cells |
0110 |
$216.35 |
$221.59 |
$5.24 |
2.42% |
|
38210 |
T-cell depletion of harvest |
0393 |
$362.55 |
$400.19 |
$37.64 |
10.38% |
|
38211 |
Tumor cell deplete of harvst |
0393 |
$362.55 |
$400.19 |
$37.64 |
10.38% |
|
38212 |
Rbc depletion of harvest |
0393 |
$362.55 |
$400.19 |
$37.64 |
10.38% |
|
38213 |
Platelet deplete of harvest |
0393 |
$362.55 |
$400.19 |
$37.64 |
10.38% |
|
38214 |
Volume deplete of harvest |
0393 |
$362.55 |
$400.19 |
$37.64 |
10.38% |
|
38215 |
Harvest stem cell concentrte |
0393 |
$362.55 |
$400.19 |
$37.64 |
10.38% |
|
38220 |
Bone marrow aspiration |
0003 |
$197.50 |
$208.26 |
$10.76 |
5.45% |
|
38221 |
Bone marrow biopsy |
0003 |
$197.50 |
$208.26 |
$10.76 |
5.45% |
|
38230 |
Bone marrow collection |
0112 |
$1,949.26 |
$2,033.73 |
$84.47 |
4.33% |
|
38240 |
Bone marrow/stem transplant |
0112 |
$1,949.26 |
$2,033.73 |
$84.47 |
4.33% |
|
38241 |
Bone marrow/stem transplant |
0112 |
$1,949.26 |
$2,033.73 |
$84.47 |
4.33% |
|
38242 |
Lymphocyte infuse transplant |
0111 |
$732.85 |
$759.70 |
$26.85 |
3.66% |
|
88184 |
Flowcytometry/ tc, 1 marker |
0433 |
$15.27 |
$16.50 |
$1.23 |
8.06% |
|
88185 |
Flowcytometry/tc, add-on |
0433 |
$15.27 |
$16.50 |
$1.23 |
8.06% |
|
88187 |
Flowcytometry/read, 2-8 |
0342 |
$15.27 |
$10.06 |
-$5.21 |
-34.12% |
|
88188 |
Flowcytometry/read, 9-15 |
0343 |
$15.27 |
$34.55 |
$19.28 |
126.26% |
|
88189 |
Flowcytometry/read, 16 & > |
0343 |
$32.75 |
$34.55 |
$1.80 |
5.50% |
|
G0364 |
Bone marrow aspirate &biopsy |
0340 |
$70.68 |
$42.69 |
-$27.99 |
-39.60% |
Intravenous Infusion of Immunoglobulin (IVIG)
CMS is finalizing its proposal to discontinue separate payment for preadministration services for IVIG (Code G0332). This payment had been initiated several years ago when there was a severe shortage of IVIG and substantial efforts were needed to acquire the product and schedule the infusion. According to CMS, since available evidence indicates that this problem has largely been resolved, the agency will no longer pay separately for the preadministration services.
Overall Hospital Outpatient Prospective Payment System (HOPPS) Payment Update
CMS projects that total payments under the Hospital Outpatient Prospective Payment System (HOPPS) will be about $30.1 billion in 2009 compared with about $28.5 billion in 2008. Hospitals will receive in total a 3.9 percent increase in payments under HOPPS. This includes a 3.6 percent increase in the market basket as well as changes to the outlier rate which adds about 0.27 percent to payments.
An important change in the HOPPS payment policy for 2009 is that for the first time Medicare payment for outpatient services is linked to the reporting of certain quality measures. In order for hospitals to receive the full outpatient payment update for 2009, hospitals must have reported data in 2008 on seven quality measures related to emergency department services and preoperative surgical care services. Hospitals that fail to meet the outpatient reporting requirements will receive a 2 percent reduction in the payment update. This policy is similar to the one established for Medicare payment of inpatient services.