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AABB > Programs & Services > Billing and Reimbursement Initiatives

AABB Billing and Reimbursement Initiatives - Archived News 

Medicare 2013 Outpatient Proposal Would Cut Payments for Several Blood Products and Increase Payments for some Stem Cell Procedures

AABB has prepared summary of key sections of the 2013 proposed rule for the Medicare Hospital Outpatient Prospective Payment System that pertain to payment rates for blood products and transfusion and cellular therapy services. The proposed rule — issued by the Centers for Medicare and Medicaid Services — calls for relatively small decreases in payments for certain widely transfused blood products (e.g., the payment for leukoreduced RBCs would fall from $198.90 in 2012 to $193.19 in 2013). Proposed payments for most bone marrow and stem cell procedures would increase but in general still lag below the actual costs of these services. Comments on the proposed rule are due to CMS by Sept. 4.

Summary of 2012 Medicare Outpatient Payments for Blood Products and Transfusion and Cellular Therapy Procedures

AABB has prepared a summary of the 2012 Medicare Hospital Outpatient Prospective Payment System rule, providing details about the payment rates for blood products and transfusion and cellular therapy services. The final rule — issued in early November by the Centers for Medicare and Medicaid Services — calls for modest increases in payments for most frequently transfused blood products and bone marrow and stem cell processing services. However, payments continue to lag behind the actual costs of most of these products and services. Providers are urged to bill using the appropriate blood-related and stem cell processing codes so that CMS can obtain better cost data to help determine payments for these products and services in the future. The new payment system takes effect Jan. 1, 2012.

Summary of 2011 Medicare Outpatient Payments for Blood Products and Services and Stem Cell Processing

AABB has prepared a summary of the 2011 Medicare Hospital Outpatient Prospective Payment System rule, providing details about the payment rates blood products and transfusion and cellular therapy services. The final rule — issued in early November by the Centers for Medicare and Medicaid Services — calls for modest changes to payments for most blood products and bone marrow and stem cell processing services. However, payments continue to lag behind the actual costs of these products and services. Providers are urged to bill using the appropriate blood-related and stem cell processing codes so that CMS can obtain better cost data to help determine payments for these products and services in the future. The new payment system takes effect Jan. 1, 2011.

CMS Issues FY 2011 Hospital Inpatient PPS Final Rule

AABB has prepared a brief summary of key transfusion medicine and cellular therapy related provisions included in Medicare’s fiscal year 2011 rule on hospital inpatient services. The Centers for Medicare and Medicaid Services released its final rule for the hospital inpatient prospective payment system PPS for fiscal year 2011 on July 30, 2010. In this rule, CMS finalizes new, additional codes for ABO incompatibility reactions as well as autologous and allogeneic bone marrow/stem cell transplants.

Medicare 2011 Outpatient Proposal Would Cut Payments for Certain Blood Products and Only Modestly Increase Payments for Stem Cell Processing

AABB has prepared a summary of sections of the 2011 proposed rule for the Medicare Hospital Outpatient Prospective Payment System that pertain to payment rates for blood products and transfusion and cellular therapy services. The proposed rule — issued by the Centers for Medicare and Medicaid Services — calls for small increases, and in some instances decreases, in payments for blood products (e.g., $189.06 for leukoreduced red blood cells in 2011, compared with $186.73 in 2010; and $448.96 for platelets, pheresis, down from $469.11 in 2009). Proposed payments for laboratory bone marrow and stem cell processing codes increased modestly but still lag below the actual costs of these services. Comments on the proposed rule are due to CMS by Aug. 31.

AABB Comments on Proposed 2011 Hospital Inpatient PPS Rule

In comments sent to the Centers for Medicare and Medicaid Services, AABB raises concerns regarding provisions included in the agency’s 2011 proposed rule for the hospital inpatient prospective payment system (PPS) which would replace ABO incompatibility reaction ICD-9-CM code 999.6 and Rh incompatibility reaction code 999.7 with a longer list of more detailed codes. AABB notes that the newly proposed codes would unnecessarily confuse hospital providers and billers. AABB also has recommended that CMS further refine its codes for classifying autologous and allogeneic bone marrow/stem cell transplants.

Frequently Asked Questions and Answers Regarding Billing for Stem Cell Processing

AABB consulted experts to provide responses to frequently asked member questions regarding the billing and coding of stem cell processing, particularly in light of Medicare's recent recognition of certain stem cell processing codes. 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 FAQs provide helpful information.

Summary of 2010 Medicare Outpatient Payments for Blood Products and Stem Cell Processing

AABB has prepared a summary of the 2010 Medicare Hospital Outpatient Prospective Payment System rule, providing details about the payment rates blood products and cellular therapy services. The final rule — issued this month by the Centers for Medicare and Medicaid Services — calls for modest changes to payments for most blood products and bone marrow and stem cell processing services. However, payments continue to lag behind the actual costs of these products and services. Providers are urged to bill using the appropriate stem cell processing codes so that CMS can obtain better cost data to help determine payments for these services in the future. The new payment system takes effect Jan. 1, 2010.

AABB Comments on Medicare Proposed 2010 Outpatient Payments for Blood Products and Stem Cell Processing

In comments filed with the Centers for Medicare and Medicaid Services, AABB urged the agency not to implement proposed cuts in payments for many blood products. Instead, AABB recommended that CMS base the 2010 payment rates for blood products on the 2009 rates increased by the 3.1 percent change in the government-recognized blood and organ producer price index from July 2008 to July 2009. In separate joint comments, AABB, the American Society for Blood and Marrow Transplantation and the National Marrow Donor Program asked the agency not to implement its proposed change to classify allogeneic bone marrow/stem cell transplants as “inpatient only” procedures and therefore not pay for such services in an outpatient setting. A final hospital outpatient rule will be published this fall, with new payment rates taking effect January 1, 2010.

CMS Clarifies MUE Policy

CMS has issued a letter clarifying a policy relating to Medically Unlikely Edits. In an April 14, 2009 letter, CMS states that "providers cannot utilize an Advanced Beneficiary Notice under any circumstance to bill a beneficiary for a [unit of service] denied due to an MUE even if the denial is upheld due to lack of medical necessity on appeal." CMS developed MUEs to reduce the paid claims error rate for Medicare Part B claims. An MUE for a HCPCS/CPT code is the maximum units of service that a provider would report under most circumstances for a single beneficiary on a single date of service. CMS automatically denies all units of service billed in excess of the CMS-determined criteria for the number of units. Excess charges beyond the MUE level may not be billed to the beneficiary. The majority of MUEs are posted on CMS' Web site.

Medicare Proposed 2010 Outpatient Rule Would Cut Payments for Certain Blood Products and Only Modestly Increase Payments for Stem Cell Processing

AABB has prepared a summary of sections of the CY 2010 proposed rule for the Medicare Hospital Outpatient Prospective Payment System which pertain to payment rates for blood products and transfusion and cellular therapy services. The proposed rule — issued this month by the Centers for Medicare and Medicaid Services — calls for very small increases and in some instances modest decreases in payments for the most frequently transfused blood products (e.g., $188.92 for leukoreduced Red Blood Cells in 2010, versus $187.93 in 2009; and $468.66 for platelets, pheresis, versus $461.09 in 2009). However, the agency proposes significant decreases in the payments for some infrequently used blood products. Proposed payments for laboratory bone marrow/stem cell processing codes modestly increase, but still lag notably below the actual costs of these services. Comments on the proposed rule are due to CMS by August 31.

CMS Proposed Rule Would Reflect Hospital Blood Costs in Inpatient “Market Basket”

In its proposed rule for 2010 payments for hospital inpatient services, the Centers for Medicare and Medicaid Services (CMS) took the long-awaited step of proposing to use a new prospective payment index (PPI) that would specifically track changes in the cost of blood products to hospitals. For years, AABB, along with the American Red Cross, America’s Blood Centers and AdvaMed, has asked the agency to include such an index in calculating its overall inflationary adjustments to the “market basket” for inpatient services. Currently, in calculating price changes for blood and blood products for the hospital market basket CMS uses another PPI which has no relationship to blood costs. In comments to the agency, AABB, ARC, ABC and AdvaMed commend the agency for taking this important step. The proposed rule is expected to take effect on October 1, 2009.

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)

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