July Coding Changes: Pathogen Reduced Platelet Products &Testing Introduction

CMS has released two new HCPCS Q codes for pathogen reduced platelet products and associated pathogen testing. The new codes are effective July 1, 2017. Charge Master or Revenue Cycle teams should review this new regulatory guidance with owners of applicable transfusion medicine, blood bank or laboratory Charge Master sections. Because two codes are replacing a single code for Medicare billing, it’s important that blood bank staff be made aware of this coding update to synchronize revisions to entry screens, billing systems and associated protocols.

Two codes replace HCPCS P9072 (Platelets, pheresis, pathogen reduced or rapid bacterial tested, each) that will be inactivated July 1:

  • Q9987- Pathogen(s) test for platelets o OPPS SI = S o APC 1493 o Added as a procedure code o Use a Revenue Code similar to your other blood testing charges
  • Q9988- Platelets, pheresis, pathogen reduced, each unit o OPPS SI = R o APC 9536 o Added as a blood product o Use a Revenue Code similar to your other blood product charges

 

 

HCPCS Descriptor Challenge

The description for Q9988 includes the word “pheresis”. This term was absent from the code descriptor in the CMS 3rd Quarter 2017 OPPS update guidance but was present in the HCPCS masterfile updates. It was acknowledged as an inadvertent omission by our CMS contact. We were told that the October 2017 OPPS update will include this revision, but it’s safe to assume that the term is included.

Also note that HCPCS Q9987 and Q9988 are temporary codes. They are slated to be replaced in January 2018 if preliminary recommendations of the HCPCS Workgroup are finalized (source: June 8, 2017 HCPCS Public Meeting minutes).

 

Why the Changes?

Bacterial contamination of platelet products is the most significant infectious risk in transfusion today. The FDA has issued guidance that urges hospitals to mitigate this risk by utilizing pathogen-reduced platelets or by performing secondary bacterial testing on platelet products received from suppliers beginning at day 4 when pathogens levels, if present, can be detected. This secondary or ‘late’ testing is usually performed once within the 24 hour period prior to transfusion as a safety measure.

 

As early as 2015, the need arose for new HCPCS P codes to report pathogen-reduced platelet and plasma products that approved by the Food and Drug Administration. CMS added three new codes: 

  • HCPCS P9070- Plasma, pooled multiple donor, pathogen reduced, frozen, each unit
  • HCPCS P9071- Plasma (single donor), pathogen reduced, frozen, each unit 
  • HCPCS P9072- Platelets, pheresis, pathogen reduced
    In May 2016, CMS issued a preliminary decision to allow outpatient billing of the Verax PGD® Test, the first FDA cleared rapid test to detect bacterial contamination in platelet products. CMS did not establish a new code for this test. Instead, it revised the description of the HCPCS code established in 2016 for pathogen-reduced platelets (P9072) to include the use of pathogen-reduction technology or rapid bacterial testing.
  • HCPCS P9072- Platelets, pheresis, pathogen reduced or rapid bacterial tested, each unit

The revised code and updated payment rate were published by CMS on November 1, 2016 in the Hospital Outpatient Prospective Payment System (OPPS) Final Rule for CY2017.

Unfortunately, CMS’ decision to revise the description of HCPCS P9072 was not a good decision. CMS received a request to eliminate the phrase “or rapid bacterial tested” from the description of P9072. The request was included in the agenda of the HCPCS public meeting held on June 8, 2017 where the applicant pointed out that a Rapid Bacterial Tested (RBT) product is not the same as a pathogen reduced product. A pathogen reduced product is manufactured using a recently FDA-approved pathogen reduction process. The HCPCS workgroup concurred that a revision was warranted and took the following actions:

For the July 2017 update, the HCPCS Workgroup inactivated HCPCS P9072 and replaced the code with two new HCPCS codes effective July 1, 2017. CMS Transmittal R3783 states the following:

“Specifically, to report either of the services described by HCPCS P9072 based on the code descriptor in effect for January 1, 2017 – June 30, 2017, providers must instead report either HCPCS code Q9988 (Platelets, pathogen reduced, each unit) or Q9987 (Pathogen(s) test for platelets) effective July 1, 2017. We note that HCPCS code Q9987 should be reported to describe the test used for the detection of bacterial contamination in platelets as well as any other test that may be used to detect pathogen contamination.”

 

The July 1st coding changes and associated payment rates will be published in this quarter’s ChargeAssist® quarterly updates based on the CMS guidance.