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Comments to CMS on Proposed Changes to the Hospital Inpatient Prospective Payment Systems and Fiscal Year 2011 Rates – 6/17/10

June 17, 2010

Marilyn Tavenner
Acting Administrator
Centers for Medicare and Medicaid Services
Department of Health and Human Services
Attention: CMS-1498-P
P.O. Box 8011
Baltimore, MD 21244-1850

Re: Proposed Changes to the Hospital Inpatient Prospective Payment Systems and Fiscal Year 2011 Rates (CMS-1498-P)

Dear Ms. Tavenner:

AABB appreciates the opportunity to comment on the Centers for Medicare and Medicaid Services (CMS) proposed rule updating the Medicare hospital inpatient prospective payment system (PPS) for fiscal year 2011.  AABB (formerly known as the American Association of Blood Banks) is a professional association dedicated to advancing transfusion medicine and cellular therapies.  AABB’s members include approximately 1,800 institutions, including hospital-based blood banks and laboratories, transfusion services and blood and bone marrow collection facilities, as well as approximately 8,000 individuals involved in blood, bone marrow, cord blood and peripheral blood stem cell collection, processing, storage and infusion. 

Blood Incompatibility Codes

AABB offers the following comments regarding the proposed addition of new ICD-9-CM diagnosis codes to replace 999.6 (ABO incompatibility reaction) and 999.7 (Rh incompatibility reaction).  We are concerned that adding notably to the granularity of codes in this area will unnecessarily confuse hospital providers and billers.  There does not appear to be a significant need for these new codes since there were so few cases reported using the more general 999.6 – 23 cases in October 2008 through June 2009. 

AABB recognizes the vital need to reduce the number of transfusions of ABO incompatible units of blood.  Reducing payment for such medical errors provides an important incentive to implement policies and procedures to prevent errors.  However, it is critical to distinguish between error-related and non-error-related unavoidable incompatibilities.  Therefore, it is important to distinguish, as CMS has, between ABO incompatibilities and other unavoidable incompatibilities.   

Bone Marrow Transplants

Currently, autologous and allogeneic bone marrow/stem cell transplants are assigned to a single MS-DRG.  Several organizations, including AABB, requested CMS to analyze the costs of allogeneic and autologous and to establish two separate DRGs if justified by the cost differences. We greatly appreciate CMS’ willingness to conduct this cost analysis which demonstrated that the costs of allogeneic transplants are substantially higher than those for autologous procedures.  We strongly endorse CMS’ proposal to establish MS-DRGs 014 and MS-DRG 015 to report these services. 

AABB is concerned, however, that further refinements in these codes are needed to properly account for patient severity of illness and associated hospital resource use, as well as differentiations between related and unrelated donor transplant cases.  As an increasing number of Medicare beneficiaries receive transplants it is critical that Medicare policies reflect as accurately as possible the actual costs of these lifesaving procedures, which can vary significantly depending on whether an unrelated donor is needed and/or the patient has preexisting comorbidities requiring additional resource use.  AABB would welcome the opportunity to work with the agency and other interested parties, including the National Marrow Donor Program and American Society for Blood and Marrow Transplantation, to further improve reimbursement for stem cell transplants. 

Thank you for your attention to these matters.  If you have any questions or require additional information, please contact me at 301-215-6554. 


Theresa L. Wiegmann, JD
Director, Public Policy