CMS Proposed 2009 HOPPS Payments Include Modest Increases for Most Blood Products and Cellular Therapy Procedures

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CMS Proposed 2009 HOPPS Payments Include Modest Increases for Most Blood Products and Cellular Therapy Procedures

Under a proposed rule for 2009 Medicare payments for hospital outpatient services, the Centers for Medicare and Medicaid Services (CMS), has proposed modest payment increases for most frequently transfused blood products. However, reimbursement for many blood products and services would continue to lag behind actual costs. In addition, Medicare payments for bone marrow and stem cell procedures would remain woefully inadequate, despite small proposed payment increases for such services.

Payments for Blood Products

For calendar year 2009, CMS has proposed payments for blood and blood products based on simulated medians calculated using CY 2007 hospital claims data. For example, CMS proposes to pay $192.43 for a unit of leukocyte-reduced red blood cells, compared with its $185.15 payment in 2008. Overall, payments would be increased for most blood products, particularly the most frequently transfused products. Payments for 25 of the 34 blood products would increase under the CMS proposal. Unfortunately, however, the actual average hospital acquisition costs for most blood products remain significantly higher than the proposed 2008 CMS payments.

The following table compares the proposed 2008 payment rates for blood products with current Medicare payment rates:

Payments for Blood Components

HCPCS	Description	2008 Final APC	2009 Proposed APC	2008 Final Payment Rate	2009 Proposed Payment Rate	% Change
P9010	Whole blood for transfusion	0950	0950	$254.85	$237.56	-6.78%
P9011	Blood split unit	0967	0967	$149.10	$30.65	-79.44%
P9012	Cryoprecipitate each unit	0952	0952	$41.24	$43.86	6.35%
P9016	RBC leukocytes reduced	0954	0954	$185.15	$192.43	3.93%
P9017	Plasma 1 donor frz w/in 8 hr	9508	9508	$67.03	$77.22	15.20%
P9019	Platelets, each unit	0957	0957	$69.50	$78.95	13.60%
P9020	Platelet rich plasma unit	0958	0958	$363.50	$386.74	6.39%
P9021	Red blood cells unit	0959	0959	$129.66	$139.95	7.94%
P9022	Washed red blood cells unit	0960	0960	$277.03	$314.11	13.38%
P9023	Frozen plasma, pooled, sd	0949	0949	$73.87	$62.31	-15.65%
P9031	Platelets leukocytes reduced	1013	1013	$107.51	$106.76	-0.70%
P9032	Platelets, irradiated	9500	9500	$121.72	$169.00	38.84%
P9033	Platelets leukoreduced irrad	0968	0968	$139.94	$142.85	2.08%
P9034	Platelets, pheresis	9507	9507	$441.03	$472.96	7.24%
P9035	Platelet pheres leukoreduced	9501	9501	$499.53	$518.35	3.77%
P9036	Platelet pheresis irradiated	9502	9502	$417.71	$460.52	10.25%
P9037	Plate pheres leukoredu irrad	1019	1019	$630.08	$658.96	4.58%
P9038	RBC irradiated	9505	9505	$195.18	$257.68	32.02%
P9039	RBC deglycerolized	9504	9504	$347.23	$362.60	4.43%
P9040	RBC leukoreduced irradiated	0969	0969	$240.27	$257.32	7.10%
P9043	Plasma protein fract,5%,50ml	0956	0956	$93.88	$76.49	-18.52%
P9044	Cryoprecipitate reduced plasma	1009	1009	$83.69	$86.79	3.70%
P9048	Plasmaprotein fract, 5%, 250ml	0966	0966	$215.23	$211.83	-1.58%
P9050	Granulocytes, pheresis unit	9506	9506	$1,387.55	$1,677.37	20.89%
P9051	Blood, l/r, cmv-neg	1010	1010	$147.90	$157.93	6.78%
P9052	Platelets, hla-m, l/r, unit	1011	1011	$645.94	$680.70	5.38%
P9053	Plt, pher, l/r cmv-neg, irr	1020	1020	$686.54	$656.60	-4.36%
P9054	Blood, l/r, froz/degly/wash	1016	1016	$218.81	$300.83	37.48%
P9055	Plt, aph/pher, l/r, cmv-neg	1017	1017	$488.74	$480.29	-1.73%
P9056	Blood, l/r, irradiated	1018	1018	$147.13	$236.90	61.01%
P9057	RBC, frz/deg/wsh, l/r, irrad	1021	1021	$373.99	$477.77	27.75%
P9058	RBC, l/r, cmv-neg, irrad	1022	1022	$263.46	$299.55	13.70%
P9059	Plasma, frz between 8-24hour	0955	0955	$77.93	$73.49	-5.70%
P9060	Fr frz plasma donor retested	9503	9503	$52.64	$65.99	25.36%

Payments for Bone Marrow and Stem Cell Processing Services

CMS has proposed very modest increases in payments for bone marrow/stem cell processing codes 38207-38215, which were first recognized by the agency in 2008. The proposed payment rate for Codes 38207-38209 (cryopreservation and thawing codes) is $222.94 (compared with $216.35 now), and the proposed payment for Codes 38210-38215 (cell depletion codes) is $397.83 (compared with $362.55). It should be noted that since these payments are based on 2007 claims data, any more recent adjustments that hospitals have made in their charging practices are not yet reflected in CMS’ payments. Hospitals are encouraged to take steps now to ensure that their charges accurately reflect the actual costs of providing these services since CMS will base future payments on such charge data.

The following table compares 2008 payment rates for bone transfusion and cellular therapy procedures with CMS’ proposed 2009 payments for these services:

2009 Proposed HOPPS Procedural Payments
CPT/ HCPCS	Description	2008 Final APC	2009 Proposed APC	2008 Final Payment Rate	2009 Proposed Payment Rate	%Change
36430	Blood transfusion service	0110	0110	$216.35	$222.94	3.05%
36440	Bl push transfuse, 2 yr or <	0110	0110	$216.35	$222.94	3.05%
36450	Bl exchange/transfuse, nb	0110	0110	$216.35	$222.94	3.05%
36455	Bl exchange/transfuse non-nb	0110	0110	$216.35	$222.94	3.05%
36511	Apheresis wbc	0111	0111	$732.85	$769.81	5.04%
36512	Apheresis rbc	0111	0111	$732.85	$769.81	5.04%
36513	Apheresis platelets	0111	0111	$732.85	$769.81	5.04%
36514	Apheresis plasma	0111	0111	$732.85	$769.81	5.04%
36515	Apheresis, adsorp/reinfuse	0112	0112	$1,949.26	$2,020.15	3.64%
36516	Apheresis, selective	0112	0112	$1,949.26	$2,020.15	3.64%
36522	Photopheresis	0112	0112	$1,949.26	$2,020.15	3.64%
38205	Harvest allogenic stem cells	0111	0111	$732.85	$769.81	5.04%
38206	Harvest auto stem cells	0111	0111	$732.85	$769.81	5.04%
38207	Cryopreserve stem cells	--	0344	$216.35	$222.94	3.05%
38208	Thaw preserved stem cells	--	0344	$216.35	$222.94	3.05%
38209	Wash harvest stem cells	--	0344	$216.35	$222.94	3.05%
38210	T-cell depletion of harvest	--	0110	$362.55	$397.83	9.73%
38211	Tumor cell deplete of harvest	--	0110	$362.55	$397.83	9.73%
38212	Rbc depletion of harvest	--	0110	$362.55	$397.83	9.73%
38213	Platelet deplete of harvest	--	0110	$362.55	$397.83	9.73%
38214	Volume deplete of harvest	--	0110	$362.55	$397.83	9.73%
38215	Harvest stem cell concentrate	--	0110	$362.55	$397.83	9.73%
38220	Bone marrow aspiration	0003	0003	$197.50	$213.45	8.08%
38221	Bone marrow biopsy	0003	0003	$197.50	$213.45	8.08%
38230	Bone marrow collection	0123	0112	$1,949.26	$2,020.15	3.64%
38240	Bone marrow/stem transplant	0123	0112	$1,949.26	$2,020.15	3.64%
38241	Bone marrow/stem transplant	0123	0112	$1,949.26	$2,020.15	3.64%
38242	Lymphocyte infuse transplant	0111	0111	$732.85	$769.81	5.04%
88184	Flowcytometry/ tc, 1 marker	0433	0433	$15.27	$16.41	7.47%
88185	Flowcytometry/tc, add-on	0433	0433	$15.27	$16.41	7.47%
88187	Flowcytometry/read, 2-8	0433	0433	$15.27	$10.23	-33.01%
88188	Flowcytometry/read, 9-15	0433	0433	$15.27	$34.96	128.95%
88189	Flowcytometry/read, 16 & >	0343	0343	$32.75	$34.96	6.75%
99363	Anticoag mgmt, init	Code Not Recognized By OPPS
99364	Anticoag mgmt, subseq	Code Not Recognized By OPPS
G0364	Bone marrow aspirate &biopsy	0002	0340	$70.68	$42.57	-39.77%

Intravenous Immunoglobulin (IVIG)

For several years, CMS has been paying an additional amount for the pre-administration costs of acquiring IVIG. This payment is in addition to the payment for the drug itself and its administration. A temporary code, G0332, was established to report this service which was intended to compensate for the time and effort to locate and obtain the product in a difficult market. In 2009, CMS proposes to no longer pay separately for pre-administration, but instead consider this a packaged service. CMS states that additional payment was intended to be a temporary measure during a period of market fluctuations for IVIG and the agency has concluded that market conditions have improved and this payment is no longer necessary.

AABB will submit comments to CMS regarding the proposed rule. The proposed rule will be posted in the July 18, 2008 edition of the Federal Register.

Last modified on 7/22/2008 12:33:32 PM