ASH Comments on Proposed HOPPS

2009-08-26

ASH submitted comments on proposed revisions to the Hospital Outpatient Prospective Payment System (HOPPS) regulations. ASH specifically addressed the proposed change to classify allogeneic bone marrow/stem cell transplants as “inpatient only” procedures and to exclude payment for hematopoietic progenitor cell harvesting for transplantation.

  • ASH urged CMS to allow physician judgment by the transplant physician to determine when to perform an allogeneic transplant in a hospital outpatient setting.
  • ASH asked CMS to withdraw the corresponding change for Code 38205 from an “E” or excluded status to an “S” status.
  • ASH urged Code 38205 continue to be paid separately under HOPPS regardless of where the transplant ultimately occurs because the proposed “bundling” policy is overly complicated and burdensome.

ASH developed its comments after discussion with the American Association of Blood Banks, American Society of Bone Marrow Transplants, and the National Marrow Donor Program.

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