Organizational Resistance and Resilience
Change seems to be everywhere in the blood community these days - evolving business relationships, new technologies such as pathogen reduction, and emerging transfusion-transmitted biological agents such as Babesia. The ever-changing regulatory landscape is another key element in our environment that can create commotion in the blood industry.
Preventing regulatory calamities is a priority and both government agencies and members of the blood community strive for thoughtful change. This can be difficult in an increasingly complex healthcare world. That is why proposed changes require a period of public comment and regulatory response prior to implementation of final rules, regulations, and guidance. The public comment period provides an opportunity for stakeholders to resist the creation of regulatory policy that may have unanticipated negative effects. The public comment period also serves to create resilience in our industry, as we are able to develop partnerships and evolve strategies to adapt in advance of implementation.
The Centers for Medicare & Medicaid Services (CMS) on July 8 released the proposed 2016 Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems rule, available on the CMS website. Of specific interest to the blood community, the proposed rule includes a request for comment on significant reductions in Medicare payment for the most commonly transfused products in the outpatient setting (see page 1).
ABC is reviewing this proposal closely for possible impacts and opportunities for influencing reimbursement for blood and blood products and to inform the blood community's response during the public comment period, ending August 31. ABC will partner with other key stakeholders including AABB, the American Red Cross, and the American Hospital Association to strengthen our collective voice advocating for blood centers and the communities that we serve. Keep your eye out for more details about how you can get involved in this vital advocacy initiative.
CMS releases updates to inpatient and outpatient rules annually. These are just one example of the plethora of proposed regulations that ABC reviews on behalf of its members.
While the Department of Health and Human Services (HHS) houses most entities of interest to blood operators (i.e., the Food and Drug Administration, CMS, the Centers for Disease Control and Prevention, and the National Institutes of Health), it may be surprising to note that there are other government departments that we monitor for their impact on the blood industry, such as the Department of Justice and the Department of Homeland Security. A comprehensive and anticipatory posture provides the best strategic readiness to preemptively respond swiftly and effectively to external environmental changes that impact our members.
Christine Zambricki, DNAP, CRNA, FAAN, Chief Executive Officer;CZambricki@americasblood.org