Recently, the Centers for Medicare & Medicaid Services (CMS) has recognized prehospital blood transfusions in a proposed a rule. Specifically, the proposed rule includes recognition of low titer O+ whole blood transfusion as part of the Ambulance Fee Schedule (AFS). This change may not immediately impact reimbursement rates, but it sets precedent regarding the clinical importance of blood transfusion in this setting while also laying the groundwork for recognition and reimbursement of prehospital blood transfusions by private insurance companies.
In the proposed rule in which CMS recognizes prehospital blood transfusions, the agency explicitly noted that, “we do not have the authority to provide an additional payment, such as an add-on payment for the administration of whole blood transfusion therapy (WBT) under the AFS.” The agency also stated that most ambulances that carry blood would already be classified as advanced life support level 2 (ALS2), and therefore the expected impact is minimal. Additionally, CMS cited the Prehospital Blood Transfusion Initiative Coalition (PHBTIC) highlighting the importance and impact of the work of this coalition. ABC sits on the PHBTIC Steering Committee.
Comments to the proposed rule are due September 9th. ABC plans to submit comments by the deadline and welcomes input from member blood centers. The proposed rule will be published in the Federal Register on July 31st.
Expanding access to blood products (including prehospital blood transfusions) remains a priority for America’s Blood Centers and a part of our advocacy agenda. The impact of low-titer group O whole blood continues to be documented in peer-reviewed research.