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Policy Perspective - April 2018

By Kate Jacobson posted 04-23-2018 11:27 AM

  
This article is part of the April 2018 edition of ASBMT eNews. Download the full issue here. 

By Stephanie Farnia, ASBMT Director of Health Policy and Strategic Relations

First, let’s talk logistics. Due to the management firm transition (read more about that decision in the March newsletter President’s Message), ASBMT staff have new emails. You can now reach me at SFarnia@asbmt.org, and I encourage you to please update your address book, as my prior email will expire soon. Normally, the lead story in the April policy column would be an overview of key issues noted in the released Medicare Inpatient Prospective Payment System (IPPS) Proposed Rule and a request for readers to send in comments on the relevant points of concern. However, the proposed rule was just released, so please look for a special off-cycle email focused on the changes that affect the HCT/CT community.

HCT  

  1. HCT/CT CMS Provider Specialty Code Clarification: As noted last fall, CMS issued a new provider specialty code (C9) for the HCT and cellular therapy field. However, this code was not automatically issued a corresponding taxonomy code by the National Uniform Claim Committee (NUCC), and a formal request process will need to be initiated. We anticipate this process to take several months and issuance of a NUCC code is not guaranteed. However, the CMS Specialty Code is still valid and useful for the purposes of the Quality Payment Program, and we encourage provider teams to update their enrollment with CMS.
  2. Post-HCT Immunizations: As many of you have noted, post-HCT immunizations are not reimbursed by CMS. We are kicking off a project to remedy this situation and have members of the Administrative Directors’ Special Interest Group (SIG), the Pharmacy SIG and the Infectious Disease Committee represented on a working group to address the issue. Look for more information in future newsletter updates.

CAR-T

  1. CPT Codes: The process for securing CPT codes for the procedures involved with CAR-T administration are continuing and the next CPT meeting is scheduled for May 17-19 in San Antonio. Registration is open now and a public detailed agenda will be posted in the coming weeks. As a reminder, the current CPT code cycle is for codes that will go into effect for the 2020 calendar year; we anticipate discussions with the AMA Editorial Panel over the course of several CPT meetings may be necessary to secure the new set of codes.
  2. Q codes: As part of the regular quarterly updates to the CMS OPPS Addendum B file, the two Q codes associated with approved CAR-T products were posted to the file. There are a few key things to know about these codes: first, the payment rate amount is only for when the product is infused in the outpatient setting and is not subsequently admitted during the 72-hour window after infusion (for PPS hospitals); second, the minimum unadjusted copayment rate is not what patients will be required to pay when receiving this care in the outpatient setting (see the last bullet on page 4 of this resource); and finally, there are several concerns the ASBMT has regarding the inclusion of leukapheresis in the full code description and payment structure. We have posted a letter sent to CMS on this issue here and intend to voice additional concerns during the upcoming HCPCS Meeting in May, when Novartis and Kite plan to present their requests for permanent J codes that to replace the current Q codes.

HCPCS Code

Short Descriptor

SI

APC

Payment Rate

Minimum Unadjusted Copayment

Q2040

Tisagenlecleucel car-pos t

G

9081

$500,838.64

$100,167.73

Q2041

Axicabtagene ciloleucel car+

G

9035

$395,380.00

$79,076.00

 

  1. CAR-T Resource Page: In an attempt to streamline the various resources associated with CART on the ASBMT website, they have been pulled together on a single page: ASBMT CAR-T Resources. Please share with your team as a resource.
  2. CAR-T Coding and Reimbursement Town Hall: Due to high demand for information and best practices related to CAR-T billing, coding and reimbursement, our first CAR-T Town Hall will take place on Monday, April 30 from 12-1 p.m. CT via webinar. Jugna Shah and Valerie Rinkle from Nimitt Consulting will join me for a discussion of the most pressing issues members are facing, along with Q&A time for those on the phone. ASBMT members are eligible to register for the meeting; click here to sign up. This particular session is intended for the provider community only
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