Corporate Compliance

Note from Hugh

Medicare Insider, May 14, 2008

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CMS last week issued revised guidance on billing for blood and blood products to ensure correct application of the Medicare blood deductible. The Medicare blood deductible requires that beneficiaries, and not Medicare, pay for the first three units of whole blood or packed red cells received in a calendar year. However, Medicare pays for the processing and storage of those units because the blood deductible does not apply to processing and storage.

Transmittal 1495 to the Medicare Claims Processing Manual  revised chapter 3 to clarify billing requirements for whole blood and red blood cells for inpatients. The manual section clarifies that the proper revenue codes are 0381 for packed red cells and 0382 for whole blood. Note that split units of whole blood and packed red cells should be billed under 0389. Revenue code 0380 is no longer an acceptable revenue code for billing blood products. Revenue codes 0381 and 0382 trigger application of the blood deductible and revenue code 0389 will not.

CMS also used Transmittal 1495 and an accompanying MLN Matters article published last week (see below) to remind hospitals that the beneficiary is not responsible for the blood deductible if the hospital only paid processing charges for the blood, but did not pay for the actual blood product. Because some state laws prohibit payment for blood donation, and because most whole blood is donated without payment to the donor, it is commonly the case that hospitals pay blood banks for processing, but not for the blood product itself. Hospitals can verify in their contract with their blood bank how fees paid by the hospital are allocated.

If the hospital’s only cost for the blood is collection, processing, storage, delivery, etc., this represents processing costs and they are not subject to the blood deductible. They should be billed with revenue code 0390 or 0399, not revenue codes 0381 or 0382, to avoid improper application of the blood deductible. Presumably, in the case of donated blood for which the hospital paid only for processing, there would be no charges in the 038X series of revenue codes because the processing costs are billed in the 0390 or 0399 revenue codes.

~ Kimberly Anderwood Hoy, Esq.

Editor's Note: Kimberly Anderwood Hoy, director of Medicare and compliance for HCPro, is the author of this week's "Note from Hugh" in Mr. Aaron's absence.

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