America’s Blood Centers (ABC), the Association for the Advancement of Blood & Biotherapies (AABB), and the American Red Cross (ARC) have provided prehospital blood comments in response to CMS’ proposal, “to add the administration of low titer O positive whole blood (LTOWB) transfusion to the current list of advanced life support, level 2 (ALS2) procedures.”
In the joint prehospital blood comments, the blood community expresses concern that CMS’ proposed policy, “will not achieve the intended outcome of ensuring that patients have access to prehospital blood transfusions.” Specifically, ABC, AABB, and ARC outline that the proposed policy is flawed because:
- “it does not apply to all FDA-approved blood and blood components that are critical for patients requiring prehospital hemostatic resuscitation; and
- the current payment rate for ALS2 is far too low to accommodate the cost of providing pre-hospital blood transfusions.”
The blood community prehospital blood comments also state that, “CMS should consider a model that includes a prehospital blood product add-on payment that incorporates the costs associated with procuring, storing, and administering blood transfusions. Activities may include, but are not limited to, procuring blood products from entities such as blood collection establishments and hospitals, storing blood products in accordance with safety standards, and transfusing the blood safely and effectively.”
CMS previously proposed a rule that included recognition of LTOWB transfusion as part of the Ambulance Fee Schedule (AFS). CMS explicitly noted in the proposed rule that, “we do not have the authority to provide an additional payment, such as an add-on payment for the administration of whole blood transfusion therapy (WBT) under the AFS.” The agency also stated that most ambulances that carry blood would already be classified as advanced life support level 2 (ALS2), and therefore the expected impact is minimal.
ABC will continue to provide updates on its advocacy efforts as they become available.