Donald Berwick, M.D.
Centers for Medicare and Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244-1850
RE: CMS-1504-P, Proposed Changes to the Hospital Outpatient Prospective Payment System and CY 2011 Payment Rates
Dear Administrator Berwick:
AABB appreciates the opportunity to comment on the proposed changes in the hospital outpatient prospective payment system (HOPPS) for 2011. AABB (formerly known as the American Association of Blood Banks) is a not-for-profit association representing individuals and institutions involved in transfusion medicine and cellular therapy. Our membership consists of nearly 2,000 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. This letter outlines our concerns relating to the proposed payment rate for blood and blood products and stem cell procedures.
APC for Stem Cell Transplantation
AABB is very concerned about the ambulatory payment classification (APC) payment rates for stem cell transplants currently assigned to APC 0112. In our judgment, the payment rate is inadequate and does not fully cover all the activities associated with this complex procedure, including donor search, harvesting bone marrow/stem cells, laboratory processing and preservation, and the actual transplant. In its February 2010 meeting, the APC Advisory Panel recommended that, in order to support stem cell transplantation, the Centers for Medicare and Medicaid Services (CMS) consider creating a composite APC or custom APC that captures the costs of stem cell acquisition performed in conjunction with recipient transplantation and preparation of tissue. CMS accepted this recommendation and indicated it will report the results of the assessment to the APC Panel at a future meeting. AABB is pleased to hear that CMS is considering establishing a composite or custom APC to more fully capture the costs of this procedure. We urge the agency to move forward with this initiative as soon as possible and would welcome the opportunity to assist CMS in this effort.
AABB appreciates that CMS has recognized the complexities surrounding blood product costs and has made a number of accommodations over the years so that the calculated rates for blood products are as fair as possible. However, AABB remains concerned that the proposed payments for many blood products do not cover the incurred costs.
In particular, AABB believes the proposed payment for leukocyte reduced red blood cells (APC 0954) of $189.06 continues to fall notably below actual costs. This payment is below the acquisition costs paid by hospitals for a unit of leukocyte-reduced red blood cells. Preliminary data from the most recent National Blood Collection and Utilization Survey funded by the Department of Health and Human Services indicate that in 2008 hospitals paid on average far greater than $200 per unit of leukoreduced RBCs. AABB encourages CMS to consult this data when it is published later this year. Moreover, it does not reflect hospitals' significant overhead costs associated with storing, managing, processing and delivering these blood components. Because this is the most frequently transfused blood product, it is important that the corresponding payment most accurately reflect the hospitals’ associated costs to avoid significant underpayments to hospitals. AABB urges CMS to take steps to ensure that payments for all blood products more accurately reflect hospital costs, including both related acquisition and overhead expenses. We would welcome the opportunity to work with CMS in further addressing this important issue.
Thank you again for the opportunity to offer these comments. AABB looks forward to continuing to work with CMS to improve the process for calculating the payments for stem cell procedures and blood products.
Theresa L. Wiegmann, JD
Director of Public Policy