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 OPPS blood reimbursement reform, a priority of the 2023 ABC Advocacy Agenda. In a comment letter to CMS in response to the CY 2024 Hospital Outpatient Prospective Payment (OPPS) and Ambulatory Surgical Center Payment Systems Proposed Rule, the organizations encouraged CMS to revise its proposed essential medicines policy. The hospital OPPS blood reimbursement reform comment letter asked the agency to:
- “include blood and blood products, and
- ensure that the payments are sufficient to cover all costs associated with procuring and maintaining essential medicines, including a “buffer stock” of blood and blood products.”
Specifically, the hospital OPPS blood reimbursement reform comment letter explains that, the blood community appreciates CMS’ “commitment to ensuring access to essential medicines as part of supply chain resiliency and public health preparedness. By recognizing the importance of essential medicines, CMS is taking a proactive approach to safeguarding public health during emergencies and crises. Nevertheless, we have reservations about the proposed policy’s effectiveness in achieving its intended goals, as it excludes blood and blood products from the category of essential medicines…The proposed rule defines “essential medicines” as the 86 essential medicines prioritized in the “Essential Medicines Supply Chain and Manufacturing Resilience Assessment” report, developed by the Assistant Secretary for Preparedness and Response (ASPR). This report exclusively focuses on small molecules and therapeutic biologics and explicitly omits blood and blood products from its analysis and scope ‘due to differences in their supply chains.'”
The hospital OPPS blood reimbursement reform comment letter stated, “Conversely, blood and blood products are explicitly classified as essential medicines on the U.S. Food and Drug Administration (FDA) Executive Order 13944 “List of Essential Medicines, Medical Countermeasures, and Critical Inputs…The blood supply is a critical aspect of emergency preparedness and unlike other pharmaceuticals and biologics, blood cannot be manufactured to meet demand. Therefore, we strongly urge CMS to include blood and blood products within the scope of the proposed payment policy for ensuring access to essential medicines. By including blood and blood products in the proposed payment policy, CMS would further enhance its emergency preparedness efforts, contributing to the resilience of the health care system and the well-being of patients.”
Finally, the hospital OPPS blood reimbursement reform comment letter concluded by noting that, “we are concerned that CMS’ proposed payment rates for most blood and blood products for CY 2024 are lower than the reimbursement rates for 2023 and are inadequate. As highlighted earlier, in late 2021 and early 2022 the country experienced a significant blood shortage, which may be affecting the proposed reimbursement rates for blood and blood products. We urge CMS to collaborate with the blood community to ensure that the reimbursement rates for these vital
medical resources are sufficient.”
ABC also requested blood reimbursement reform to another CMS proposed rule.
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