Medicare Inpatient Prospective
Payment System Preview
In anticipation of the FY2018 Inpatient Prospective Payment System (IPPS) proposed rule, the National Marrow Donor Program® (NMDP)/Be The Match® and the ASBMT, communicated our concerns to the Centers for Medicare & Medicaid Services (CMS) leadership. There are three major areas that we are targeting in this IPPS cycle:
||Creating Parity between Solid Organ Transplant and HCT Payment Policies
We understand that the current Medicare reimbursement for HCT is in adequate and makes it difficult for your centers to provide HCT to Medicare beneficiaries. Therefore, we have asked CMS to change the current payment policy for HCT cell acquisition to align with solid organ transplant. Our proposal suggests that CMS remove cell acquisition from the current MS-DRG 014 to pay for the acquisition separately from the inpatient procedure/hospital stay. Solid organ transplant, including living kidney donation, is currently reimbursed under this payment policy. This change would allow each hospital to create separate acquisition charges for 1) related donors; 2) marrow/PBSC; and 3) cord blood. We believe that this change is within CMS’s authority and would ensure that our hospitals are more adequately reimbursed, particularly for purchased services, and would help protect patient access to care.
||Clarification around Revenue Code 0815
In the CY2017 Outpatient Prospective Payment System final rule, CMS made a number of significant changes to the way outpatient HCT is reimbursed, including the creation of a new revenue code, 0815, for our services. CMS stated in the final rule that they would be “implementing a code edit beginning in CY2017 that will require revenue code 0815 to be on a claim with CPT code 38240…” CMS has not designated this code to be used in an inpatient setting, thus we have asked that CMS clarify their guidance around the use of revenue code 0815 in the inpatient setting and apply the code edit to inpatient claims as well. These changes will help CMS to capture the full cost of HCT, including acquisition, for data analysis and future rate-setting.
||MLN Matters: Guidance on Site of Service for Transplants
Last October, CMS released MLN Matters article SE1624, which addressed the February 2015 Office of the Inspector General (OIG) report on their review of Medicare claims related to HCT. The article has caused a lot of confusion our community because it states that, “stem cell transplants are typically performed in the outpatient setting” and that, “hospitals may have incorrectly thought that stem cell transplantation was on CMS’s list of inpatient-only procedures”. The vast majority of HCTs are performed in the inpatient setting and according to 2015 Medicare data, only 3% of HCTs were done in the outpatient setting. We have asked CMS to retract and revise their guidance to avoid confusion and any potential negative impact to patient care.
Please look for more information from us once the FY2018 IPPS proposed rule is released. We expect a proposed rule in April, with an open comment period. As in the past, we will be asking for your help to contact CMS and advocate for critical payment and access issues that impact your hospitals and patients. If you have any questions about our proposed policy changes, please contact Alicia Silver at firstname.lastname@example.org.
We are excited to introduce our new Director of Public & Payer Policy, Susan Leppke. Susan comes to the NMDP/Be The Match with an extensive background in solid organ transplant policy and data research. In her new role, Susan will lead both the Payer Policy and Legislative Relations teams. We look forward to connecting you with Susan in the coming months.
Preservation & HCT
are drafting a position statement to address the importance of commercial
coverage and benefits for fertility preservation for our patients. As many of
you know, losing fertility after receiving gonadotoxic treatments, which HCT
almost always requires, can be quite devastating for many patients. If you have
any experience with referring patients to a fertility specialist and would like
to provide insight into the process, please contact Theresa Hwee at email@example.com. Thank you in advance for your help!
Please submit comments: Federal Appropriations for NMDP/Be The Match
By the end of April, Congress will decide how much to appropriate to programs that provide essential funding to NMDP/Be The Match. Historically, Congress has demonstrated broad bipartisan support for Americans in need of a bone marrow or cord blood transplant through the C.W. Bill Young Cell Transplantation Program (Program) and National Cord Blood Inventory (NCBI).
We again ask Congress to continue its commitment by providing additional funds to these programs operated by the NMDP / Be The Match on behalf of the government. Modestly increasing the amount that Congress funds over current levels will allow Be The Match to recruit additional ethnically diverse donors and add more cord blood units to the Program and NCBI. Each new donor or cord blood unit gives hope to someone in need of a life-saving transplant.
Help us ask Congress to continue funding and maintain its commitment to the Program and NCBI. We cannot do this without your help! Act now and submit a comment to your members of Congress to support NMDP/Be The Match. It’s easy and takes only a few minutes. You can customized our pre-written letter and send it automatically to your legislators.
Medicare Cost Report
Webinar Slides Available
The slides and a
recording from Jugna Shah and Valerie Rinkle’s recent NMDP webinar, “HCT &
The Medicare Cost Report” are now available on our website.
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If you have any questions or need additional information, please contact the Payer Policy Team at PayerPolicy@nmdp.org. All of our resources are available on our website: Network.BeTheMatchClinical.org/Reimbursement.