AABB Comments on Proposed 2009 HOPPS Payments
AABB has submitted comments to the Centers for Medicare and Medicaid Services (CMS) noting the agency's ongoing practice of reimbursing for blood products at rates notably below hospitals' actual acquisition rates.  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. AABB has prepared a summary  of the proposed rule's treatment of blood products and transfusion and cellular therapy procedures.

Summary of 2008 Medicare Outpatient Payments for Blood Products and Stem Cell Processing
AABB has prepared a summary of the 2008 Medicare Hospital Outpatient Prospective Payment System rule, providing details about the payment rates for blood products, cellular therapy services, clotting factors and IVIG. The final rule — issued this month by the Centers for Medicare and Medicaid Services — calls for increases to payments for several bone marrow and stem cell processing services. The increases were made in response to concerns raised by AABB and others, although they are lower than requested.  Providers are urged to bill using the new stem cell processing codes so that CMS can obtain better cost data to help determine payments for these services in the future. Payments for most blood products increased modestly compared to 2007 rates. The new payment system takes effect Jan. 1, 2008.

AABB Issues Updated Billing Guide for Transfusion and Cellular Therapy Services
AABB has posted an updated version 4.0 of the AABB Billing Guide for Transfusion and Cellular Therapy Services.  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 apheresis, blood derivatives, tissue and bone.

Frequently Asked Questions and Answers Regarding Billing for Blood and Transfusion Services
AABB consulted several experts to provide responses to frequently asked member questions regarding the billing and coding of blood products and transfusion services reimbursable under the Medicare program.  These FAQs address a broad range of billing and coding issues, including billing for autologous blood, split, irradiated or frozen units, and transfusion services.  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 frequently asked questions and answers provide helpful information relating to Medicare billing policies. 

CMS Responds to Inquiry Regarding Appropriate Billing for Blood and Related Services
The Centers for Medicare and Medicaid Services (CMS) has responded to a request from the blood banking community for clarification of agency guidance regarding billing for blood and related services.  In late 2005, AABB, the American Red Cross (ARC), America’s Blood Centers (ABC) and the Advanced Medical Technology Association (AdvaMed) wrote to CMS commenting on CMS Transmittal 496 (March 4, 2005) and providing recommendations for improved guidance related to both outpatient and inpatient reimbursement for blood products and services.  AABB has summarized CMS’ responses to the blood community, as included in a September 29, 2006, letter to AABB.

Blood community’s letter to CMS  (PDF)
CMS September 29, 2006 letter  (PDF)

CMS Proposed 2008 HOPPS Payments Include Modest Increases for Blood Products, Notable Improvements for Some Cellular Therapy Procedures
Under a proposed rule for 2008 Medicare payments for hospital outpatient services, the Centers for Medicare and Medicaid Services, 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. CMS proposed more dramatic increases for some bone marrow and stem cell related procedures and for the first time has agreed to recognize certain CPT codes for bone marrow/stem cell processing. AABB has prepared a summary of the proposed rule's treatment of blood products and transfusion and cellular therapy procedures.

AABB Responds to CMS Proposal on Clinical Trial Coverage
In an effort to improve reimbursement to patients involved in clinical trials, AABB has submitted a response to the Centers for Medicare and Medicaid Services (CMS) concerning its proposed revisions to the Medicare National Clinical Research Policy. In a May 9 letter, AABB stressed the important role clinical research plays in advancing quality care for patients requiring transfusions as well as those battling certain cancers and other life-threatening conditions treated with hematopoietic stem cell transplants. AABB requested that CMS amend its proposed policy to ensure that Medicare beneficiaries have access to approved clinical trials. The association also requested that CMS not abandon its current policy allowing for coverage of investigational new drug (IND)-exempt studies, such as those involving the off-label use of drugs or biologics — including cellular therapy products that are likely to be approved but used off-label in trials during the coming years. Additionally, AABB urged CMS to cover trials under investigational device exemption (IDE), noting that in some instances FDA considers cellular product processing procedures and the resultant product a biologic subject to IND review and in other instances considers them a device subject to IDE review.

CMS Releases Final 2007 Outpatient Rule and Blood Payments
The Centers for Medicare and Medicaid Services (CMS) recently announced its final 2007 payment rates for blood and transfusion, bone marrow and hematopoietic stem cell related services provided in the outpatient setting.  For a complete list of these rates, which take effect Jan. 1, 2007, and additional background information, click here. 

AABB Urges CMS to Increase 2007 Outpatient Payments for Blood Products
Commenting on Medicare’s 2007 Hospital Outpatient Prospective Payment System proposed rule, AABB urged the Centers for Medicare and Medicaid Services (CMS) to increase its proposed payment of only $177 for leukocyte-reduced red blood cells, the most frequently transfused component. As a related matter, AABB has produced a summary of Medicare's recently proposed 2007 payments for outpatient blood products and transfusion medicine and cellular therapy services. 
Click here to view the comments. (PDF)

AABB Asks Medicare to Improve Payments for Cell Therapy Procedures
AABB recently wrote to the Centers for Medicare and Medicaid Services (CMS) expressing concerns about Medicare payments for bone marrow and peripheral blood progenitor cell processing services.  AABB stated in the letter that it strongly believes that CMS payments for such services need to be adjusted to reflect the actual costs of providing potentially life-saving care.  The specific CPT codes referenced in the letter include 38207-38215 and 38204. 

Click here to view the letter. (PDF)