The national blood community hospice rule comments are available in response to the proposed hospice rule and request for information (RFI) from the Centers for Medicare & Medicaid Services (CMS). Specifically, America’s Blood Centers (ABC), the Association for the Advancement of Blood & Biotherapies (AABB), and the American Red Cross (ARC) have submitted joint comments to the CMS fiscal year (FY) 2025 proposed rule titled, “Hospice Wage Index and Payment Rate, Hospice Conditions of Participation Updates, and Hospice Quality Reporting Program Requirements.” The blood community hospice rule comments, “urge CMS to improve Medicare beneficiaries’ access to end-of-life care by providing incremental, separate payments, leveraging the established blood product HCPCS code sets and associated rates for palliative blood transfusions furnished under the Medicare hospice benefit.”
The proposed rule solicited comments regarding potential implementation of a separate payment mechanism to account for high intensity palliative care services, including blood transfusions. It also included a request for information (RFI) explaining that CMS is considering a major potential shift away from a closed hospice bundled payment to allow patient access to services like blood transfusions.
The blood community hospice rule comments noted that, “[o]ur organizations commend CMS for the focused attention on removing barriers and expanding access to palliative blood transfusions for Medicare beneficiaries under the hospice benefit. Palliative blood transfusions relieve debilitating symptoms that negatively impact patients’ quality of life. Recognizing and explicitly acknowledging the coverage of palliative blood transfusions under the hospice benefit constitutes a crucial step forward in enhancing access to this essential therapy. However, to truly optimize access to palliative blood transfusions, revisions to Medicare’s payment policy are imperative.”
ABC, AABB, and the American Red Cross explained in the blood community hospice rule comments that few hospice organizations offer blood transfusions due to the Medicare per diem payment amount being, “far too low to cover costly yet helpful palliative interventions, such as blood transfusions.” The comments stated that, “hospice providers lack accurate data on the number of patients who would benefit from palliative transfusions, as many of these patients never even contact the hospice provider after being told by their treating physician that transfusions will be unavailable. This uncertainty further complicates the justification for the infrastructure and staffing costs required to provide blood transfusions. As a result, Medicare beneficiaries reliant on blood transfusions may experience delays in hospice enrollment, premature exit from hospice care, or frequent transitions in and out of hospice settings. Such outcomes not only compromise the quality of care but also contribute to increased overall costs.”
The blood community hospice rule comments concluded by stating that, “with continued education about the availability of blood transfusions under the hospice benefit, carving out payments for blood transfusions from the per-diem payment will remove a substantial barrier to care and improve end of life care for patients and their families.”
An archive of ABC comments and letters is available on the ABC website.