Billing and Reimbursement for Stem Cell Processing
Frequently Asked Questions and Answers
As a service to our members, AABB has consulted experts to provide responses to your questions regarding the coding and billing of stem cell processing, particularly in light of Medicare’s recent recognition of certain stem cell processing codes. The responses below reflect the opinions of those experts, their presentations regarding these codes before the CPT editorial board and the American Medical Association/Specialty Society Relative Value Scale Update Committee (RUC) and the related discussions of those committees. For further background information regarding stem cell processing codes, see CPT Changes 2003 – An Insider’s View (CPT is a registered trademark of the American Medical Association). AABB assumes no legal liability for the use of these responses in seeking reimbursement for services reimbursable under the Medicare program. You are advised to consult persons responsible for the coding and billing of services at your institution, as well as the Medicare contractor for your geographical location, to ensure the correct coding and billing of services provided at your institution.
1. What is new with reimbursement for stem cell processing?
The Centers for Medicare and Medicaid Services (CMS) announced in the fall of 2007 that it would recognize certain bone marrow and stem cell processing codes for the first time, starting in January 2008. The agency is now collecting cost data on cell processing procedures, which it will use to establish revised hospital outpatient reimbursement rates in the future.
2. Why is this important?
Since future revenue will be based on what cell processing facilities are now charging, it is imperative that charges accurately reflect the true costs of these procedures. Currently, CMS’ payments for stem cell processing are woefully inadequate. For example, in 2008, CMS is paying only $216.35 for codes 38207-38209 (cryopreservation, thawing) and $362.55 for codes 38210-38215 (cell depletion). Facilities must supply CMS with accurate cost data in order to improve future payments.
3. Why should I care about Medicare?
Other third party payers often base their payment and reimbursement policies on Medicare policies. If Medicare reimburses appropriately for stem cell processing, it is much more likely that other payers will follow suit.
4. What should my facility do?
Facilities should review their Chargemaster (CDM) data and be sure they are accurate. Many facilities have not historically included all of the applicable costs that are permissible.
5. Where do I obtain Chargemaster information?
The department that manages your cell processing billing should have this. It may be the department of Oncology, Bone Marrow transplant, hospital billing or the administrators that contract with payers.
6. What should be included in the costs?
In general, in calculating their costs for stem cell processing procedures, facilities may include:
§ testing (except microbial testing);
§ technician and lab director time;
§ supplies;
§ machine use;
§ machine depreciation;
§ space costs;
§ quality assurance testing of an individual product;
§ amortization of laboratory construction cost; and
§ overhead.
Once an estimate is made of the total costs of performing each code, hospitals should apply their usual markup for that department in setting their actual charge level.
7. What are the codes I should be looking at?
§ 38207 Cryopreserve stem cells
§ 38208 Thaw preserved stem cells
§ 38209 Wash harvest stem cells
§ 38210 T-cell depletion of harvest
§ 38211 Tumor cell depletion of harvest
§ 38212 RBC depletion of harvest
§ 38213 Platelet depletion of harvest
§ 38214 Volume deplete of harvest
§ 38215 Harvest stem cell concentrate
The following table outlines costs that may be included for these codes.
|
Stem Cell Processing Codes and Related Costs |
|
Code |
Description |
Services Included |
|
38207 |
Cryopreserve stem cells
|
· For cryopreservation and storage of bone marrow or peripheral blood progenitor cells
· Include technician time, laboratory supplies, machinery, machinery depreciation, space costs, quality testing, and all flow cytometry tests used for quality assurance testing
· If mononuclear cell processing was done prior to cryopreservation, it should be billed separately.
|
|
38208 |
Thaw preserved stem cells |
· For transplant preparation of hematopoietic progenitor cells; thawing of a previously cryopreserved progenitor cell harvest (without wash)
· Include technician time used in thawing process, supplies, equipment, equipment depreciation, space costs, and post-thaw visibility testing |
|
38209 |
Wash preserved stem cells
|
· For transplant preparation – thaw and wash – of hematopoietic cells
· Thawing and washing of a previously cryopreserved progenitor cell harvest
· Include technician time, machinery, machinery depreciation, supplies, and post-thawing/wash viability testing |
|
38210 |
T-Cell depletion of harvest |
· Include technician time machinery, machinery depreciation, reagent kits, disposable kits and related supplies and materials, space costs, and quality assurance testing
· Also include tests to evaluate efficacy of T-cell depletion, test to evaluate viability after T-cell depletion, and flow cytometry testing (pre and post)
· If cryopreservation is needed, it may be billed separately
· If mononuclear separation not routinely performed as part of T-cell depletion, then may be billed separately
· If mononuclear separation routinely performed as a product preparation step, include costs in this charge
|
|
38211 |
Tumor cell depletion of harvest |
· For autologous transplantation
· Include technician time, machinery, machinery depreciation, reagent kits, disposable kits and related supplies and materials, space costs, and quality assurance testing
· Also include testing to document efficacy of tumor purging and post-tumor purging cell viability
· Cryopreservation is always done and therefore should not be billed separately
· If mononuclear cell separation is routinely done, it should be included in cost; if not, and only performed occasionally, do not include in this code but bill separately
· Flow cytometry assessment should be included and cannot be billed separately |
|
38212 |
Red Blood Cell Removal |
· For a fresh allogeneic harvest; removal of RBCs in preparation for transplant; or red cell depletion for a major ABO incompatible bone marrow harvest
· Include technician time, machinery, machinery depreciation, supplies, and space costs
· Also include testing of efficacy of RBC removal, testing of viability of progenitor cells after RBC removal, and flow cytometry testing for quality assurance
· NOTE: Should only use this code if doing a Hetastarch (HES) separation |
|
38213 |
Platelet depletion of harvest
|
· For peripheral blood progenitor cell harvest with a platelet soft spin
· Preparation of platelets for a platelet addback
· Include technician time, machinery, machinery depreciation, supplies, and space costs |
|
38214 |
Volume deplete of harvest
|
· For plasma reduction for a fresh bone marrow harvest
· Include technician time, testing, machinery, machinery depreciation, supplies, and space costs
|
|
38215 |
Harvest stem cell concentrate
|
· For mononuclear cell preparation for ABO incompatibility on a fresh bone marrow harvest or for further cell processing procedures
· Include technician time, testing, machinery, machinery depreciation, supplies, and space costs
|
8. I don’t see a code for fresh marrow. How is the laboratory testing and documentation billed?
For fresh products which have no processing performed other than quality control testing, the costs should be rolled into the infusion charge.
9. If a patient receives an infusion of four bags, is this four infusions or one?
The infusion charges apply to a single infusion event and are capped at one per day.
10. What about physician professional fees?
CMS has not yet approved codes for professional fees for supervision of stem cell processing. Professional fees can be billed to many private payers; billing may depend on type of contract physician/outpatient facility has negotiated with private payer.
AABB welcomes your feedback and invites you to send suggestions to celltherapy@aabb.org