America’s Blood Centers (ABC), the Association for the Advancement of Blood & Biotherapies, and the American Red Cross have submitted joint comments to the Centers for Medicare and Medicaid Services (CMS) advocating for blood reimbursement reform, a priority of the 2023 ABC Advocacy Agenda.
The comment letter requesting blood reimbursement reform, a response to the CY 2024 Physician Fee Schedule Proposed Rule, asks CMS to:
- establish a new clinical labor code for a therapeutic apheresis nurse with a labor rate reflecting the required skills and experience; and
- increase the payment rates assigned to these CPT codes to reflect the total cost of the procedures.
Specifically, the comment letter requesting blood reimbursement reform states, “the CPT codes for therapeutic apheresis are insufficient to ensure patient access in all care settings where the procedure can be safely performed. Indeed, these challenges of inconsistent and insufficient coverage are present in Medicare as well as various private and governmental insurance options, and often result in patients either forgoing therapeutic apheresis or transferring to a different, and more expensive, care setting to access the procedure…Blood establishments often utilize their nursing staff to service multiple hospitals and/or other providers in a region and meet the rigorous scheduling, technical, and compliance demands required by patients who depend on this essential procedure…Due to the additional training and high demand for specialized nurses, the average hourly wage and annual salaries of these professionals is significantly higher than the labor rate of a general nurse, which is currently used by CMS for therapeutic apheresis. We believe that the establishment of a therapeutic apheresis nurse category with a labor rate reflecting the required skills and experience is an essential step to ensuring appropriate reimbursement for these procedures. In addition to devaluing the labor rate, the total reimbursement for therapeutic apheresis fails to appropriately account for the total cost of these procedures, including blood product costs, additional supplies such as collection kits, additional medical and nursing time, and specialized equipment that requires ongoing maintenance.
ABC also requested blood reimbursement reform to another CMS proposed rule.