CARDIOVASCULAR
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MEDICARE POLICY AND CONTINUED PATIENT ACCESS

PROPOSED MEDICARE 2020 PAYMENT CHANGES

On April 23, 2019, the Centers for Medicare and Medicaid Services (CMS) issued its proposed rule for the 2020 Inpatient Prospective Payment System (IPPS). With the release of this proposed rule, CMS has opened a 60-day public comment period and will be accepting comments on their proposals through June 24, 2019. They are expected to release their final rule in early August, 2019 which goes into effect October 1, 2019.

Below you will find a summary of the proposed changes in reimbursement policy for extracorporeal membrane oxygenation (ECMO) as well as guidance on how to submit comments on the proposed rule. Key to the proposed changes is a consolidation of multiple MS-DRG assignments currently separated by method of cannulation into a single DRG, an important acknowledgment from CMS that method of cannulation does not have significant bearing on hospital resources.

It is important to note that Medicare coding and payment assignments (MS-DRGs) do not necessarily align to product indications – procedures using a pump and oxygenator in a configuration other than a cardiopulmonary bypass circuit may map to MS-DRGs for ECMO, independent of duration of support. The indications for Abbott's CentriMag Pumps are located in the indications and important safety information section at the bottom of this page.

This is only a proposed rule and CMS expects public stakeholder comments to assist in their final rule deliberation. Instructions for how to comment are located below.

BACKGROUND

Last year, CMS created new codes for delineation of ECMO procedures by method of cannulation:

  • ECMO, central (5A1522F)
  • ECMO, peripheral veno-arterial (5A1522G)
  • ECMO, peripheral veno-venous (5A1522H)

In the absence of a public comment period and clear data analysis, CMS finalized these changes for the peripheral ECMO approaches which resulted in payment decreases of 30-80%. Due to advocacy by ELSO and the Society of Thoracic Surgeons, CMS is now proposing to restore peripheral ECMO procedures (both VA and VV) to MS-DRG 003 with a proposed base payment rate of $118,740. CMS acknowledges initial claims data and those procedures supported by ELSO Registry data demonstrated hospital resources to treat these types of patients are resource intensive regardless of the method of cannulation.

Abbott supports this recommendation as it is in line with removing payment barriers limiting appropriate patient access. If this proposal is finalized, reimbursement for the impacted MS-DRGs will improve substantially and alleviate the financial strain faced by acute MCS programs across the country since the 2019 rule was enacted. This proposal is favorable because it would ensure continued patient access to life-saving acute therapies that require significant hospital resources to offer.

 

PROPOSED DRG REASSIGNMENT
ICD-10 PCS Descriptor DRG Assignment
(FY2019)
Proposed DRG Assignment
(FY2020)
5A1522F ECMO, Central MS-DRG 003 MS-DRG 003
5A1522G ECMO, peripheral veno-arterial MS-DRG 207, 291, 296, 870
5A1522H ECMO, peripheral veno-venous MS-DRG 207, 291, 296, 870

 

 

PROPOSED CHANGE IN REIMBURSEMENT
MS-DRG FY2019 Reimbursement MS-DRG FY2020 Reimbursement
207 $34,190 003 $118,740
291 $8,219
296 $9,381
870 $38,459

GUIDE TO SUBMITTING COMMENTS

CMS will be accepting public comments on this proposal until June 24, 2019 11:59PM ET. Comments are submitted online through the Federal Register website.

Below are some key points to consider when submitting comments:

  • Including your name, profession and affiliation.
  • Describing your clinical practice and/or your institution’s experience with treating patients who need cardiopulmonary support.
  • Presenting the clinical impact of acute mechanical circulatory support at your institution and the intensity of resources involved in providing this type of therapy regardless of cannulation method.
  • Explaining any access challenges faced by your center under the current reimbursement structure and the importance of improving hospital reimbursement by restoring peripheral approaches for extracorporeal support to MS-DRG 003.

For additional information, please go to the FY2020 Proposed Inpatient Hospital Rule and refer to pages 15-19.


ADDITIONAL QUESTIONS?

Contact Abbott:
vadreimbursement@abbott.com

IMPORTANT SAFETY INFORMATION
INDICATIONS AND IMPORTANT SAFETY INFORMATION

INDICATIONS FOR USE*


Rx Only

Important Safety Information

Brief Summary: Prior to using these devices, please review the Instructions for Use for a complete listing of indications, contraindications, warnings, precautions, potential adverse events and directions for use.

CentriMag™ Extracorporeal Blood Pumping System Indications for Use [510(k) Clearance; 6-hour use]: The CentriMag Blood Pump is indicated for use with the 2nd Generation CentriMag Primary Console to pump blood through the extracorporeal bypass circuit for extracorporeal circulatory support for periods appropriate to cardiopulmonary bypass (up to six hours). It is also indicated for use in extracorporeal support systems (for periods up to six hours) not requiring complete cardiopulmonary bypass (e.g. valvuloplasty, circulatory support during mitral valve reoperation, surgery of the vena cava or aorta, liver transplants etc.). This device is not designed, sold, or intended for use except as indicated.

CentriMag Blood Pump Contraindications [510(k) Clearance; 6-hour use]: The CentriMag Blood Pump is contraindicated for use as a cardiotomy suction device. It is also contraindicated for patients who are unable or unwilling to be treated with heparin or an appropriate alternative anti-coagulant.

DISCLAIMER

View our Privacy Policy and Terms and Conditions for additional information.

This document and the information contained herein is for general information purposes only and is not intended, and does not constitute legal, reimbursement, business, or other advice. Furthermore, it does not constitute a representation or guarantee of cost-effectiveness, and it is not intended to increase or maximize payment by any payer. Nothing in this document should be construed as a guarantee by Abbott regarding cost effectiveness, expenditure reduction, reimbursement or payment amounts, or that reimbursement or other payment will be received. The ultimate responsibility for determining cost-effectiveness and obtaining payment/reimbursement remains with the customer. This includes the responsibility for accuracy and veracity of all claims submitted to third-party payers. Also note that actual costs for products and services and any related expenditures vary, and that the information presented herein is based on the assumptions, variables, and data presented. In addition, the customer should note that laws, regulations, and coverage policies are complex and are updated frequently, and, therefore, the customer should check with its local Medicare Administrative Contractor often and should consult with legal counsel or a financial or reimbursement specialist for any questions related to cost-effectiveness, expenditure reduction, billing, reimbursement or any related issue. This information does not guarantee coverage or payment at any specific level, and Abbott does not advocate or warrant the appropriateness of the use of any particular code. This update reproduces information for reference purposes only. It is not provided or authorized for marketing use.

CAUTION: This product is intended for use by or under the direction of a physician. Prior to use, reference the Instructions for Use, inside the product carton (when available) or at medical.abbott/manuals for more detailed information on Indications, Contraindications, Warnings, Precautions and Adverse Events.

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