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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.