America’s Blood Centers (ABC), the Association for the Advancement of Blood & Biotherapies (AABB), and the American Red Cross have asked the Centers for Medicare & Medicaid Services (CMS) for adequate blood reimbursement and the inclusion blood and blood products in the list of essential medicines in the Fiscal Year (FY) 2025 Hospital Inpatient Prospective Payment Systems (IPPS) proposed rule. The joint comments submitted by the blood community to the agency in response to the proposed rule also recommended that CMS address adequate blood reimbursement concerns by, “ensur[ing] that the payments are sufficient to cover all costs associated with procuring and maintaining essential medicines, including a ‘buffer stock’ of blood and blood products.”
The essential medicines list would provide some hospitals with funding to cover the IPPS portion of creating a six-month supply stockpile of medications classified as essential medicines. The blood community explained in the rationale supporting the recommendation for the inclusion of blood in the essential medicines list that, “blood and blood products are explicitly classified as essential medicines on the U.S. Food and Drug Administration (FDA) Executive Order 13944 ‘List of Essential Medicines, Medical Countermeasures, and Critical Inputs’” and are recognized as, “essential for addressing various medical conditions, including trauma, surgeries, cancer treatments, and other life-saving interventions. The blood supply is a critical aspect of emergency preparedness and unlike other pharmaceuticals and biologics, blood cannot be manufactured to meet demand. Therefore, we strongly urge CMS to include blood and blood products within the scope of the proposed payment policy for ensuring access to essential medicines.”
Additionally, the comments described how the inclusion of blood and blood products as essential medicines in the FY 2025 IPPS proposed rule would be, “a proactive step toward safeguarding public health and enhancing the overall resilience of the health care system.” Specifically, the blood community explained that, “[t]he COVID-19 pandemic exposed vulnerabilities in the blood supply chain, underscoring the critical need for a steady and accessible reservoir of these vital medical resources. Hospitals and healthcare providers faced significant challenges in ensuring an adequate supply of blood and blood products for patient care during the pandemic.”
The comments concluded by stating that, “[u]nlike other essential medicines, blood must be constantly and regularly collected from donors in the community. Furthermore, blood has a limited shelf life, with red blood cells lasting up to 42 days and platelets for only five days. During disasters and emergencies, it is the blood on the shelf that saves lives. Hence, establishing a payment policy for creating and storing a ‘buffer stock’ of blood and blood products would contribute to a more holistic framework that addresses routine and emergency health care needs.”
ABC has previously advocated for the inclusion of blood and blood products on the essential medicines list as a part of blood reimbursement reform. This remains a key part of the ABC Advocacy Agenda, a focus of Blood Advocacy Week, and is a priority for the blood community.
The FY 2025 IPPS proposed rule does include a 3 percent rate increase which is reduced by a 0.4 percent productivity adjustment resulting in a proposed payment increase of 2.6 percent over FY 2024.