The ACBSCT is concerned that the proposed outpatient C-APC 5244 payment rate of $15,267, published in the Federal Register on July 14, 2016, is insufficient to cover costs of procurement from different stem cell sources. The proposed payment rate does not account for the different acquisition and treatment costs associated with different sources of Hematopoietic Stem Cell Transplants (HSCTs). The ACBSCT recommends that distinct reimbursement rates be developed for different blood stem cell sources.
Based on a review by the ACBSCT of data presented at the American Society of Hematology (ASH) 2015 (Atallah, EA et al; Blood 126;195, 2015 (abstract)), and the acknowledgement that Myelodysplastic Syndromes (MDS) is an established indication for transplantation among patients younger than age 65, and to ensure that access to transplantation for Medicare beneficiaries continues, the ACBSCT recommends that CMS take one of two courses of action with regard to this indication:
Revise its current National Coverage Decision (NCD) to eliminate the requirement of a Coverage with Evidence Development (CED) to specify MDS as a covered indication for HCT based on reported outcomes to date,
Authorize continuation of the Center for International Blood and Marrow Transplant Research (CIBMTR) observational study under CED to allow for continuing accrual of patients through the time of any relevant modification to the NCD based on the results of the BMT CTN trial.
We request that CMS ensure a mechanism for interim coverage of Hematopoietic Stem Cell Transplant (HSCT) for MDS during the National Coverage Analysis process for either course of action.