October 01, 2021
AABB, America’s Blood Centers (ABC) and the American Red Cross (ARC) urged the Centers for Medicaid and Medicare Services (CMS) Administrator Chiquita Brooks-LaSure to revise the payment rate for HCPCS code P9099 (unclassified blood products), which the agency set at the rate of the lowest-cost blood product (P9043 (Infusion, plasma protein fraction (human), 5 percent, 50 ml).
In their comments, the organizations thanked the agency for establishing a code that enables providers to report unclassified blood products but shared their concern that the de minimis payment rate could have the unintended effect of discouraging the adoption and implementation of new items and services. Furthermore, they encouraged CMS to adopt the recommendation of the CMS Advisory Panel on Hospital Outpatient Payment, which suggested that CMS authorize the Medicare administrative contractors to compensate hospitals on the basis of reasonable cost for new blood products billed with HCPCS code P9099.
Additionally, AABB, ABC and ARC encouraged CMS to reassign the HCPCS code used for large volume delayed sampling (LVDS) of leukocyte-reduced apheresis platelets and leukocyte-reduced whole blood platelets to adequately reflect the additional cost of LVDS testing. They also urged CMS to work with manufacturers and the blood community to educate providers on how to bill for blood components, including new blood products that are billed using P9099, and to expeditiously establish new billing codes and provide separate payments for these blood products and services in the hospital outpatient setting.
Additional information about the Association’s efforts to improve coverage and reimbursement policies for blood products, transfusion services and cellular therapies is available on AABB’s Coverage and Reimbursement web page.