AABB is committed to seeking enhanced and fair reimbursement for blood products, and transfusion services and cellular therapies through both education regarding the complexities of blood coding and billing, and advocacy to reimbursement policy makers.
AABB Comments on Medicare Proposed Rule Related to 2018 Hospital Inpatient Payments; Opposes Changes to Payment Policy for HCT as well as Disclosure Requirements for Accreditation Organizations
AABB submitted comments to the Centers for Medicare & Medicaid Services (CMS) on June 9, 2017 in response to the 2018 hospital inpatient prospective payment system (IPPS) proposed rule. AABB requested that (1) Medicare pay for allogeneic hematopoietic stem cell transplant (HCT) cell acquisition outside of the MS-DRG payment; and (2) CMS reassign the identified ICD-10-PCS transplant transfusion codes back into the appropriate MS-DRGs following standard pre-MDC grouping logic. In addition, AABB urged CMS to rescind its proposal that national accrediting organizations disclose accreditation survey reports and plans of correction for deficiencies on their public websites.
CMS Proposes FY 2018 Medicare Hospital Inpatient Payment Policy and a New Requirement for Accrediting Organizations
On April 28, 2017, the Centers for Medicare & Medicaid Services (CMS) published in the Federal Register a proposed rule announcing Medicare payment policy and reimbursement rates under the hospital inpatient prospective payment system (IPPS) for calendar year 2018. CMS proposes a significant change to the procedure codes for hematopoietic cell transplants (HCTs), which would result in a significant reduction in payment rates for these services. In addition, the rule includes a proposal to require accrediting organizations to publish all final accreditation survey reports and an acceptable plan of correction for any cited deficiencies on their public-facing websites. It also includes payment and policy proposals for long term care hospitals (LTCHs), including a requirement that LTCHs report transfusions as a standardized patient assessment data element beginning with the FY 2020 LTCH quality reporting program (QRP). A summary of key provisions of the proposed rule can be found here. Comments on the proposed rule must be submitted to CMS by June 13, 2017.
CMS Finalizes 2017 Medicare Hospital Outpatient Payment Policy
On November 14, 2016, the Centers for Medicare & Medicaid Services (CMS) published a final rule announcing Medicare payment policy and reimbursement rates under the hospital outpatient prospective payment system for calendar year 2017. AABB has prepared a summary of key provisions impacting transfusion medicine and cellular therapies. Despite finalizing average increases in payment rates for blood and blood products, transfusion, apheresis and stem cell procedures, and transfusion laboratory services, CMS reduced payment rates for several specific HCPCS codes in each of these categories of items and services. CMS established a new Comprehensive Ambulatory Payment Classification (C-APC) code and payment rate for allogeneic hematopoietic stem cell transplantation (HSCT). Although CMS solicited general feedback on the HCPCS P-code descriptors for blood and blood products, CMS only finalized one change; effective January 1, 2017, the HCPCS code established in 2016 for pathogen-reduced platelets (P9072) will be revised to encompass the use of pathogen-reduction technology or rapid bacterial testing.
AABB Comments on Medicare Proposed Hospital Outpatient Rule; Expresses Concern for Certain Payment Rates and Responds to Request for Feedback on Current HCPCS P-Codes for Blood Products
AABB submitted two sets of comments in response to CMS’ 2017 hospital outpatient prospective payment system (OPPS) proposed rule. In comments submitted on September 2, 2016 responding to the proposed payment rates, AABB encouraged CMS to maintain its policy of providing separate payments for blood products in the outpatient setting, expressed concern regarding proposed payment rates for certain transfusion, apheresis and stem cell procedures, and requested that CMS reconsider its method used to calculate the general reduction in payment rates for the majority of transfusion laboratory services. In separate comments responding to CMS’ solicitation for feedback on the HCPCS P-codes for blood products, AABB recommended that CMS (1) retain unique HCPCS codes for each blood product; (2) establish a not otherwise classified code for blood products; (3) improve the consistency of the descriptors throughout the blood codes, and modify certain existing codes; and (4) establish unique HCPCS codes for new products that are distinguishable from existing blood products. AABB also encouraged CMS to convene stakeholders for a collaborative workshop prior to establishing, finalizing or implementing a thoroughly revised code set for blood products. In addition, AABB submitted joint comments with America’s Blood Centers and the American Red Cross on the HCPCS codes for blood products.
CMS Issues Proposed Medicare Hospital Outpatient Payments for 2017
The Centers for Medicare and Medicaid Services (CMS) issued its calendar year 2017 proposed rule for the Hospital Outpatient Prospective Payment System (OPPS). The proposed rule, which also covers the Medicare Ambulatory Surgical Center (ASC) Payment System, includes generally modest changes to reimbursement rates for outpatient hospital services. Additionally, CMS is soliciting comments regarding the Healthcare Common Procedure Coding System (HCPCS) P-codes for blood products. A summary of key provisions of the proposed payment system can be found here. AABB will accept comments for the proposed rule through August 31, 2016. Comments may be submitted to firstname.lastname@example.org for consideration.
AABB Comments on Medicare Proposed Hospital Inpatient Rule; Expresses Concern for Reimbursement Rates of Bone Marrow and Cord Blood Transplants and Requests a Reevaluation of Blood Product Reimbursement Rates
comments to CMS in response to the proposed rule for FY2017 hospital inpatient payments. AABB highlighted the need for improved payments for bone marrow and cord blood transplants and asked the agency to address reimbursement for blood products.
AABB Supports New HCPCS Codes for Bacterial Testing and PAS Platelets
During a June 1, 2016 CMS public meeting, AABB spoke in support of establishing new HCPCS codes for
bacteria tested platelets as well as platelets stored in
platelet additive solution.
AABB Comments on CMS Proposed Decision on Coverage for HSCTs for Sickle Cell Disease
comments to CMS, urging the agency to revise its proposed policy limiting coverage for hematopoietic stem cell transplants to treat sickle cell disease to patients participating in trials with concurrent control groups. AABB noted that such a requirement would limit patient access to potentially life-saving care.
AABB Billing Guide
Billing Guide is intended to assist hospitals, clinicians, billing and coding professionals involved with the utilization and subsequent billing of the services and procedures associated with the use of blood and transfusion and cellular therapies. AABB produced this guide with the generous support and cooperation of the blood sector member companies of the Advanced Medical Technology Association (AdvaMed).
Many U.S. hospitals do not bill accurately, or at all, for blood transfused in the inpatient setting. Failure to bill appropriately for blood can hinder patient access to new technologies and potentially can affect the hospital's bottom line. The
Billing Guide is intended to help hospitals bill accurately and completely for blood products and services. Though AABB does not provide any guarantees of reimbursement, the intent of this publication is to assist hospitals in understanding the billing rules and procedures that apply for Medicare and other payers.
Billing Guide is available below in PDF format for viewing and printing:
AABB Billing Guide – Version 4.0 (PDF)
AABB serves as a leading advocate before the Centers for Medicare and Medicaid Services (CMS) and Congress regarding the need for fair and timely Medicare reimbursement for blood products and services and cellular therapies. In the
inpatient arena, AABB, along with others in the blood community, has supported efforts to allow Medicare to better account for the increasing cost of blood. In particular, AABB asked Congress and CMS to create a new blood-related producer price index (PPI) to be used in calculating the change in prices for goods and services hospitals use to provide inpatient care (the so-called "market basket"). In past years, the cost of blood had been inappropriately bundled in unrelated indices for "chemicals" or "miscellaneous goods." In response, in FY 2010 CMS agreed to use a new PPI that specifically tracks changes in the cost of blood products to hospitals. The Bureau of Labor Statistics now collects data from blood centers for this separate PPI for blood and organ banks. AABB and its fellow blood organizations will continue to work to ensure that the new index does, in fact, reflect changes in blood costs as accurately as possible.
In the realm of
outpatient reimbursement, AABB was a staunch advocate for separate ambulatory payment classifications (APCs) for individual blood products and services when CMS first established the APC outpatient prospective payment system in 1998. AABB continues to support improvements in the APC system to ensure it accurately accounts for the costs of blood and reflects the increasingly complex array of blood products and services. Specifically, AABB has urged CMS to use outside cost data provided by hospitals and blood centers to establish its outpatient payment rates for blood products, rather than continuing to rely on faulty CMS data.
In response to AABB's requests, CMS issued revised guidance regarding billing for blood under the hospital outpatient prospective payment system, which took effect July 2005. This guidance can be found at
http://new.cms.hhs.gov/transmittals/downloads/R496CP.PDF. AABB, along with others in the blood banking community, continue to urge CMS to further update and improve its guidance regarding blood-related reimbursement.
AABB also is a strong advocate for improved Medicare reimbursement for bone marrow, hematopoietic progenitor cells and apheresis-related procedures. AABB, along with other interested organizations, have urged CMS to adjust its payments to hospitals for laboratory processing services associated with bone marrow and peripheral blood progenitor cell transplants to reflect their actual costs.
Finally, AABB has championed new or improved Current Procedural Terminology (CPT) codes for transfusion medicine and cellular therapy-related procedures. For example, in response to requests from AABB, the American Medical Association in 2005 issued new CPT codes for a pretransfusion electronic crossmatch test (86923) and for volume reduction of blood products (86960).
If you have questions relating to billing and reimbursement for blood products and services, please contact