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Comments to CMS on the 2015 Proposed Rule for Hospital Outpatient Prospective Payment and Ambulatory Surgical Payment Systems and Quality Reporting Programs

September 2, 2014

Marilyn Tavenner
Centers for Medicare and Medicaid Services
Attention: CMS-1613-P
Mail Stop C4-26-05
7500 Security Blvd.
Baltimore, MD 21244

Re: CMS-1613-P – Medicare and Medicaid Programs: Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs; Proposed Rule

Dear Administrator Tavenner:

AABB appreciates the opportunity to comment on the proposed changes in the hospital outpatient prospective payment system (HOPPS) for 2015. 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, cord 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 comments and concerns relating to the proposed payment rates for stem cell transplants and policies touching upon blood products and transfusion services.

Payments for Stem Cell Transplants

AABB has significant concerns about the inadequacy of Medicare payments for stem cell transplants (SCT) in the outpatient setting. CMS’ proposed reimbursement rates for SCT – $1,078 for APC 0111 and $2,901 for APC 0112 – do not come close to covering the actual costs necessary to provide these life-saving procedures.

AABB urges CMS to establish comprehensive APCs for stem cell transplant services that would assure that all related transplant services – including all ancillary services – are covered. Currently a trivial number of services are included in setting the APC rate in part because of the "single claim" requirement. Comprehensive APCs would alleviate that problem.

Payments for Transfusion-related Services

Transfusion medicine CPT codes (CPT codes 86850-86999, in most instances, cover patient-specific blood preparation services (such as crossmatching, typing and antigen screening) that are performed prior to an anticipated blood transfusion. CMS has proposed assigning APC 0345 (Level I Transfusion Laboratory Procedures) to conditional packaging. Although the services assigned to this APC frequently are provided in conjunction with a transfusion procedure, it is not uncommon for the services to be performed on blood units that ultimately are not transfused to the beneficiary. In such instances, it is likely that the blood preparation service could be the only service reported on the claim, since the hospital would not be billing for a blood product or a transfusion procedure. It is critical that separate payment for these services be available when the service is provided alone. In addition, AABB supports CMS’ proposal to continue to provide separate payment for services assigned to APC 0346 (Level II Transfusion Laboratory Procedures), rather than designate them for conditionally packaging, as they require more extensive resources.

Payments for Blood Products

AABB appreciates that CMS will continue to provide separate payments for blood products in the outpatient setting. These separate payments recognize the important role blood and individual blood products play in caring for wide range of patients. As hospitals and blood centers face increasing economic pressures, it remains critical that Medicare and other payers provide adequate payments for blood.

Thank you again for the opportunity to offer these comments. If you have any questions or require additional information, please contact AABB director of public policy, Theresa Wiegmann at +1.301.215.6554 or


Miriam A. Markowitz
Chief Executive Officer