Proposed Policy Provides Pathway Forward For Appropriate Reimbursement for Cell Acquisition for Transplants
MINNEAPOLIS – July 8, 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 proposed hospital outpatient prospective payment system (HOPPS) rule that would increase reimbursement to address the deficits marrow and cord blood transplant centers incur for specimen acquisition costs.
“We are pleased that CMS issued a proposed rule that, if finalized, 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 improvements, this proposal is a positive step in the right direction.” Specifically, CMS proposes significant changes to the payment amount and methodology for reporting costs related to bone marrow transplants, which limits the use of the outpatient setting for transplant 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 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 $15,267. This is a significant increase from the 2016 rate of $3,015. While this still does not reflect the total acquisition costs associated with unrelated allogeneic transplant, let alone other costs of the procedure, the new C-APC methodology 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 more general revenue code that 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 barriers to transplant and commend CMS for this important step forward in its proposed rule,” Dr. Chell said. “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 this problem in the inpatient setting by aligning the cellular transplant payment policy with that used in the solid organ context as well.”
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.