-- November 02 2016
Rule Provides Pathway Forward to Protect Access to Transplant in Outpatient Settings, but More Work Needs to Be Done to Protect Patient Access in Hospital Inpatient Departments
MINNEAPOLIS—November 2, 2016—The National Marrow Donor Program® (NMDP)/Be The Match®, which operates the nation’s Be The Match Registry® of potential adult volunteer marrow donors and donated umbilical cord blood units, today applauded the Centers for Medicare & Medicaid Services (CMS) for its final hospital outpatient prospective payment system (HOPPS) rule. That rule acknowledges that current rates have not been adequate to cover outpatient treatment costs including the acquisition cost for bone marrow and cord blood for transplant.
“We are pleased that CMS issued a final rule that would provide a positive pathway forward to address chronic underfunding issues among our nation’s bone marrow and cord blood transplant centers for Medicare beneficiaries seeking life-saving transplants,” said Jeffrey W. Chell, M.D., chief executive officer of the NMDP/Be The Match. “While there remains room for improvement in the reimbursement rate to pay for cell acquisition costs which transplant centers currently are under-reimbursed for, the new methodology is a step in the right direction.”
Specifically, the new rule contains significant changes to the payment amount and methodology for reporting costs related to bone marrow and cord blood transplants, which limits the use of the outpatient setting for transplant due to the significant underpayment under the current methodology.
Key aspects of the final out patient rule include the following:
- Outpatient HCT (CPT 38240) will be moved into a new Comprehensive Ambulatory Payment Classification (C-APC). This allows all of the costs submitted on an outpatient HCT claim to remain together and be averaged with other outpatient HCT claims, versus being diluted by other lower cost services in a broader, non-comprehensive APC.
- Payment for the new C-APC is proposed to be $27,752. This is a significant increase from the 2016 rate of $3,015 and the proposed rate of $15,267. While this still does not reflect the total acquisition costs associated with unrelated allogeneic transplant, let alone the other costs incurred as part of the outpatient procedure, the new C-APC methodology will allow for upward adjustment based on cost reporting practices.
- CMS has finalized a new cost center line for tracking donor procurement and related charges – 77, “Allogeneic Stem Cell Acquisition”. Currently, donor related costs are within a more general revenue code which was subject to a Cost to Charge Ratio (CCR) edit based upon broader blood products data. By having a dedicated revenue code, CMS will have a clearer understanding of these costs and better adjust rates in the future. This will apply only to allogeneic HCT.
- Acquisition charges, including NMDP fees, HLA typing, donor evaluation, collection of cells and other costs, will be specifically required to be reported in Field 42 on CMS Form 1450 (UB-04) so that CMS may assess the charges and gauge how well the C-APC payment reflects the costs of providing these services.
“We will continue to work on behalf of patients to eliminate access barriers to transplants, but we commend CMS for this important step forward in its final rule, and we look forward to working with CMS on the CY 2018 proposed rule to capture the true costs of cell acquisition and other costs for transplants in the outpatient setting.” Chell added. “While CMS’s actions will significantly improve the lives of patients struggling to beat life-threatening diseases, we look forward to continued constructive collaboration with officials at CMS to address the ongoing reimbursement rate problem in the inpatient setting – where most transplants occur and reimbursement deficits are greatest. We continue to recommend the CMS reimburse hospitals for their cell acquisition cost separate from the DRG rate, just as they do for the acquisition cost of solid organs.”
About the National Marrow Donor Program® (NMDP)/Be The Match®
The National Marrow Donor Program (NMDP)/Be The Match is the global leader in providing a cure to patients with life-threatening blood and marrow cancers such as leukemia and lymphoma, as well as other diseases. The nonprofit organization manages the world’s largest registry of potential marrow donors and cord blood units, connects patients to their donor match for a life-saving marrow or umbilical cord blood transplant, educates health care professionals and conducts research through its research program, CIBMTR® (Center for International Blood and Marrow Transplant Research®),so more lives can be saved. NMDP/Be The Match also provides patient support and enlists the community to join the Be The Match Registry®, contribute financially and volunteer.
To learn more about the cure, visit BeTheMatch.org or call 1 (800) MARROW-2.