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Proposed Policy Provides Pathway Forward For Appropriate Reimbursement for Cell
Acquisition for Transplants.
-- July 08 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 anddonated umbilical cord blood units, today applauded the Centers for Medicare & Medicaid Services(CMS) for its proposed hospital outpatient prospective payment system (HOPPS) rule that wouldincrease reimbursement to address the deficits marrow and cord blood transplant centers incur forspecimen acquisition costs.“We are pleased that CMS issued a proposed rule that, if finalized, would provide a positive pathwayforward to address chronic underfunding issues among our nation’s bone marrow and cord bloodtransplant 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 forimprovements, this proposal is a positive step in the right direction.”Specifically, CMS proposes significant changes to the payment amount and methodology forreporting costs related to bone marrow transplants, which limits the use of the outpatient setting fortransplant due to the significant underpayment under the current methodology.
Key aspects of the proposed rule include the following:
- Outpatient HCT (CPT 38240) will be moved into a new Comprehensive Ambulatory PaymentClassification (C-APC). This allows all of the costs submitted on an outpatient HCT claim toremain together and be averaged with other outpatient HCT claims, versus being diluted byother lower cost services in a broader, non-comprehensive APC.
- Payment for the new C-APC is proposed to be $15,267. This is a significant increase fromthe 2016 rate of $3,015. While this still does not reflect the total acquisition costs associatedwith unrelated allogeneic transplant, let alone other costs of the procedure, the new C-APCmethodology will allow for upward adjustment based on cost reporting practices.
- A new revenue code for tracking donor procurement and related charges has been proposed– 112.50, “Allogeneic Stem Cell Acquisition”. Currently, donor related costs are within a moregeneral revenue code which was subject to a Cost to Charge Ratio (CCR) edit based uponbroader blood products data. By having a dedicated revenue code, CMS will have a clearerunderstanding of these costs and better adjust rates in the future. This will apply only toallogeneic HCT.
- Acquisition charges, including NMDP fees, HLA typing, donor evaluation, collection of cellsand 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 paymentreflects the costs of providing these services.
“We will continue to work on behalf of patients to eliminate barriers to transplant and commend CMSfor this important step forward in its proposed rule.” Chell added. “CMS’s actions will significantlyimprove the lives of patients struggling to beat life-threatening diseases. We look forward tocontinued constructive collaboration with officials at CMS to address this problem in the inpatientsetting by aligning the cellular transplant payment policy with that used in the solid organ context aswell.”
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 cureto patients with life-threatening blood and marrow cancers such as leukemia and lymphoma, as wellas other diseases. The nonprofit organization manages the world’s largest registry of potentialmarrow donors and cord blood units, connects patients to their donor match for a life-saving marrowor umbilical cord blood transplant, educates health care professionals and conducts researchthrough its research program, CIBMTR® (Center for International Blood and Marrow TransplantResearch®),so more lives can be saved. NMDP/Be The Match also provides patient support andenlists the community to join the Be The Match Registry®, contribute financially and volunteer.