America’s Blood Centers (ABC), the Association for the Advancement of Blood & Biotherapies (AABB) and the American Red Cross submitted joint comments to the Centers for Medicare and Medicaid Services (CMS) asking the agency to expand the availability of palliative blood transfusions in hospice. The comments addressed to the proposed rule titled “Medicare Program; FY 2024 Hospice Wage Index and Payment Rate Update, Hospice Conditions of Participation Updates, Hospice Quality Reporting Program Requirements, and Hospice Certifying Physician Provider Enrollment Requirements” (CMS-1787-P).
In the comments, the organizations “focus[ed] on the request for information (RFI) on hospice utilization. Collectively, our organizations represent the nation’s blood collection establishments, transfusion services, and transfusion medicine professionals.” The blood community expressed appreciation for the agency exploring removing barriers to help ensure access to palliative blood transfusions for Medicare beneficiaries under the hospice benefit and “applauded CMS for explicit recognition that the hospice benefit covers palliative blood transfusions.”
The comments urged that “Medicare’s payment policy must be revised to achieve increased access to palliative blood transfusions.” Specifically, the organizations stated that “[w]hile hospice organizations can give blood transfusions, very few provide this essential palliative care. The Medicare per diem payment amount is far too low to cover costly yet helpful palliative interventions, such as blood transfusions.” The comments described the complexity and resource-intense nature of the blood transfusion process, and the specialization required the professionals who provide expertise throughout the transfusion process. Additionally, the organizations noted the safety measures and monitoring needed to mitigate risk in the transfusion process. “Thus, the per diem payment is insufficient to cover the expenses associated with transfusions, which limits the ability of many hospice providers to furnish these services. As a result, Medicare beneficiaries who rely on blood transfusions may delay enrollment in hospice, leave hospice, or shuttle in and out of hospice, all of which contribute to reduced quality of care and increase in overall cost.”
The blood community concluded the comments by encouraging 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.” Adding that “[t]ogether 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.” Expanding the availability of palliative blood transfusions in hospice is also one of the priorities of the 2023 ABC Advocacy Agenda and was addressed during ABC’s Blood Advocacy Week 2023.