America’s Blood Centers, AABB, and the American Red Cross submitted this comment letter to the National Highway Traffic Safety Administration (NHTSA), on behalf of the Federal Interagency Committee on Emergency Medical Services (FICEMS), in response to a request for information (RFI), Docket NHTSA-2026-2113 on the nationwide implementation of prehospital blood transfusion. The RFI sought input on achieving the national goal of 2,028 EMS agencies with active prehospital blood transfusion programs by the end of 2028. The organizations support expanding prehospital transfusion and emphasize that the blood supply is central to achieving this goal. The letter identifies two primary barriers: operational challenges for blood collectors, including donor recruitment, manufacturing requirements, blood bag supply, and product stewardship; and inadequate reimbursement under the Medicare ambulance fee schedule, which does not separately pay for blood products or field transfusion. The organizations urge FICEMS and its federal partners to fund donor recruitment, recognize the blood supply as critical infrastructure, support product-flexible and regionally tailored strategies, and encourage CMS to establish separate payment for prehospital blood products, building on the TRICARE demonstration beginning January 2027. The letter also recommends standardizing transfusion data elements in NEMSIS using ISBT 128 identifiers, strengthening traceability and hemovigilance, deepening military civilian integration, and adopting nationally recognized standards, training, and accreditation for EMS transfusion programs.
