In a significant win for community blood centers, the Centers for Medicare & Medicaid Services (CMS) has determined that all prehospital blood transfusions, not just low titer O whole blood, should qualify as Advanced Life Support Level 2 (ALS2) Procedures. Ensuring blood transfusions are available to all patients when and where they need blood is a top priority in ABC’s Advocacy Agenda. While the CMS change does not provide direct reimbursement for blood transfusions in the pre-hospital setting, it is recognition that transfusions are an important part of pre-hospital care for some patients and should be considered when evaluating the care provided in the ambulance.
In response to the Physician Fee Schedule (PFS) proposed rule published in July 2024, ABC submitted joint comments regarding blood products provided in the pre-hospital setting of care. Under the PFS proposed rule, CMS’ initial proposed policy would only have included low-titer O whole blood transfusions as ALS2 Procedures. In joint comments, ABC recommended that CMS should cover all FDA-approved blood and blood component therapies provided in the pre-hospital setting of care.
Additionally, as a member of the Prehospital Blood Transfusion Initiative Coalition (PHBTIC) steering committee, ABC signed on to comments submitted by PHBTIC urging a similar expansion of the proposed policy.
In the PFS final rule, CMS agreed with ABC noting that, “[w]e are modifying our proposed policy to add the administration of low titer O+ whole blood to the list of procedures that independently qualify as an ALS2 procedure and finalizing a policy to change the definition of ALS2 at §414.605 by including all [prehospital blood transfusion] (PHBTs) in the list of procedures that independently qualify as an ALS2 procedure. Specifically, we are modifying the definition of ALS2 at §414.605 so that the list of ALS2 procedures now includes, as a new number eight, prehospital blood transfusion, which includes the administration of low titer O+ and O- whole blood; the administration of packed red blood cells; the administration of plasma; or the administration of a combination of packed red blood cells and plasma.” The PFS final rule for calendar year (CY) 2025 also indicates that CMS is reducing average payment rates under the PFS by 2.93 percent in CY 2025, compared with CY 2024. CMS noted that, “[t]his amounts to an estimated CY 2025 PFS conversion factor of $32.35, a decrease of $0.94 (or 2.83 percent) from the current CY 2024 conversion factor of $33.29.”
Additionally, in the PFS comments to the proposed rule, ABC encouraged CMS, through the CMS Innovation Center (CMMI), to develop and implement a payment and service delivery model that incorporates pre-hospital blood transfusions into the emergency medical system including a pre-hospital blood product add-on payment to address a major barrier to expanding access to this life saving care. While CMS reiterated in the final rule that, “[we] do not have the authority to provide an additional payment, such as an add-on payment,” the agency “may consider [these suggestions] for future rulemaking.”
CMS also recently released the final rule titled, “Medicare and Medicaid Programs: Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment Systems” for CY 2025. It contains a market basket increase of 3.4 percent reduced by a 0.5 percentage point productivity adjustment. Additionally, CMS continues the use of a blood-specific cost-to-charges ratio (CCR) methodology to establish payment rates for blood and blood products, which has been policy since the 2005 rule.
ABC will continue to provide updates on its advocacy efforts as they become available.