Inpatient Prospective Payment System (IPPS)

We advocate on behalf of our network transplant centers for appropriate coverage and reimbursement for cellular therapy. Every year, the Centers for Medicare and Medicaid Services (CMS) releases an IPPS proposed and final rule that spells out payment policy for cellular therapy, including reimbursement rates, for the coming fiscal year. See below for our most recent comment letters to CMS on critical cellular therapy payment policy topics.

NMDP FY22 IPPS Comment Letter

Read Our Previous IPPS Comment Letters

NMDP FY21 IPPS Comment Letter

NMDP FY20 IPPS Comment Letter

NMDP FY19 IPPS Proposed Rule Comment Letter on Cell Acquisition Costs

NMDP FY19 IPPS Comment Letter

FY19 IPPS Final Rule Analysis 

Formal request to split MS-DRG 014

NMDP FY18 IPPS Comment Letter

NMDP ASBMT FY17 IPPS Comment Letter

Donor Search and Cell Acquisition Cost Reimbursement

Medicare’s inpatient base reimbursement rate for allogeneic HCT is approximately $70,000. The average cost of donor search and cell acquisition for adult marrow, adult PBSC, and cord blood is between $30,000-$65,000. These costs leave very few dollars remaining to cover the average 30-day inpatient stay. Transplant centers are reporting losing thousands of dollars on every Medicare patient they treat, which is financially unsustainable and could create a serious patient access issue in the future.

Working to Break Down Patient Access Barriers

NMDP’s Health Policy team is committed to securing a solution to this patient access barrier. We have had many discussions with CMS around a regulatory fix that would mirror the way solid organ reimbursement is structured. Transplant centers would receive an MS-DRG payment for the allogeneic HCT inpatient stay and a separate payment for donor search and cell acquisition to be reimbursed on a reasonable cost basis

We are disappointed to report that the FY19 proposed rule did not address allogeneic HCT cell acquisition payment policy. Lack of attention to this issue will threaten Medicare patient access to transplant.   

FY19 Final Reimbursement Data 

Fy19 Final Reimbursement MS-DRGs

FY19 Final National Cost-to-Charge Ratios

Cost to Charge Ratios

Historical Reimbursement Trends

Medicare InPateint HCT Payment IPPS Policy