Blood Community Asks CMS to Consider Alternative Reimbursement Policies for New Blood Products in OPPS Rule

September 21, 2022

AABB, America’s Blood Centers (ABC) and the American Red Cross (ARC) asked the Centers for Medicare and Medicaid Services (CMS) to consider alternative reimbursement policies for unclassified blood products in a Sept. 13 letter to CMS Administrator Chiquita Brooks-LaSure.

Under a proposed rule that would update Medicare payment rates and policies under the hospital outpatient prospective payment system (OPPS) and the ambulatory surgical center payment system for calendar year 2023, the payment rate for unclassified blood products (Healthcare Common Procedure Coding System [HCPCS] code P9099) would increase from $7.79 to $56.58.

AABB, ABC and ARC expressed their appreciation for increased payment rate for P9099 HCPCS code; however, the organizations emphasized that this rate does not represent the cost of commonly used existing products and is insufficient to cover the expected costs of innovative new products. Additionally, AABB, ABC and ARC believe that this level of payment is likely to create a financial barrier for providers offering new and innovative blood products to Medicare beneficiaries.

To address these concerns, the organizations proposed two alternative solutions. First, they suggested that CMS could change the status indicator assigned to HCPCS code P9099 to “F” to authorize Medicare administrative contractors (MACs) to pay hospitals based on reasonable cost. According to the organizations, this would allow CMS to ensure that hospitals are adequately compensated for providing Medicare beneficiaries with new and innovative blood products by reimbursing P9099 on a reasonable cost basis.

Alternatively, AABB, ABC and ARC proposed that CMS could assign Q-codes to new blood products and adopt an expedited review of coding and payment policies for novel blood products. “These temporary Q-codes should be cross-walked to the most appropriate established code and would provide hospitals with the ability to bill for new blood products that do not yet have a permanent code or are awaiting assignment to a permanent P-code,” the organizations wrote.

AABB will update the community when CMS issues a final rule for CY 2023.