Blood Community Urges CMS to Recognize Blood Products as Essential Medicines

AABB, America’s Blood Centers (ABC) and the American Red Cross (ARC) urged the Centers for Medicare and Medicaid Services (CMS) to recognize blood and blood components as essential medicines in a Sept. 11 letter to CMS administrator Chiquita Brooks-LaSure. The blood community also asked the agency to ensure that the payment rates for blood products are sufficient to cover the costs of their procurement and maintenance.

AABB, ABC and ARC requested CMS action in response to the agency’s Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System proposed rule for calendar year 2024. In the proposed rule, CMS included a request for public comment on a potential payment to establish and maintain access to 86 essential medicines. The agency’s proposed list focuses on small molecules and therapeutic biologics but omits blood and blood products “due to differences in their supply chains.”

In its response, the blood community emphasized that the Food and Drug Administration considers blood and blood products to be essential for addressing a various medical conditions, including trauma, surgeries, cancer treatments and other life-saving interventions. Furthermore, AABB, ABC and ARC believe that by including blood and blood products in the proposed payment policy, CMS would further enhance its emergency preparedness efforts, contributing to the resilience of the health care system and the well-being of patients.

AABB, ABC and ARC also requested that CMS ensure that payments are sufficient to cover the costs of maintaining a “buffer stock” of blood and blood products. The organizations stated that establishing a payment policy for creating and storing a “buffer stock” of blood and blood products would contribute to a more holistic framework that addresses routine and emergency health care needs.

The statement also addressed the agency’s proposed payment rates for most blood and blood products for CY 2024, which are lower than the reimbursement rates for 2023 and are inadequate.

“As highlighted earlier, in late 2021 and early 2022 the country experienced a significant blood shortage, which may be affecting the proposed reimbursement rates for blood and blood products,” the blood community wrote. “We urge CMS to collaborate with the blood community to ensure that the reimbursement rates for these vital medical resources are sufficient.”