September 13, 2023
AABB, America’s Blood Centers (ABC) and the American Red Cross (ARC) issued a joint letter to the Centers for Medicare and Medicaid Services (CMS) this week asking the agency to take steps to establish a new labor code for a therapeutic apheresis nurse and increase payment rates associated with the total cost of therapeutic apheresis procedures. The organizations submitted the request to CMS administrator Chiquita Brooks-LaSure in response to the agency’s Physician Fee Schedule Proposed Rule for calendar year 2024.
Therapeutic apheresis is a well-established procedure used as a primary, adjunctive and supportive treatment for a range of hematological, neurological, renal and autoimmune disorders. However, AABB, ABC and ARC believe that the current procedural terminology (CPT) code payment rate for therapeutic apheresis are insufficient to ensure patient access in all care settings where the procedure can be safely performed.
To expand access to this essential procedure, AABB, ABC and ARC asked CMS to establish a new clinical labor code for a therapeutic apheresis nurse. Therapeutic apheresis is a time-intensive procedure that requires unique and specialized staff involvement compared to traditional medical and nursing models of care.
Due to additional training requirements and the complexity of the procedure and equipment, the average hourly wage and annual salaries of therapeutic apheresis professionals is significantly higher than the labor rate of a general nurse, which CMS currently uses for therapeutic apheresis. The organizations believe that establishing a therapeutic apheresis nurse category with a labor rate reflecting the required skills and experience is an essential step to ensuring appropriate reimbursement for these procedures.
Furthermore, the blood community believes that the total reimbursement for therapeutic apheresis fails to appropriately account for the total cost of these procedures. This includes the cost of blood products, additional supplies, medical and nursing time and specialized equipment that requires ongoing maintenance. Accordingly, AABB, ABC and ARC asked CMS to increase the payment rates assigned to these CPT codes to reflect the total cost of the procedures.