Managing new billing codes for CMV antibody negative blood products

A colleague in Wisconsin reports that according to Medicare's Healthcare Common Procedure Coding System (HCPCS) Coding Update, a new set of blood product codes, including those for CMV antibody negative blood products (P9051, P9053, and P9055), became effective in 2004. Information about these new product codes could be found in a Powerpoint slide set (no longer available) from the "2004 Reimbursement Alert for Laboratories and Pathologists" audio program, Washington G2 Reports Jan 21, 2004.

According to the inquiring colleague, the new codes are put out by the AMA and their use is mandated by Medicare (CMS). The Wisconsin colleague laments that the use of these new codes is complex because his hospital is not supplied by a blood bank using ISBT-128. Thus, the technologists must manually enter the new codes when doing billing/inventory/issuing/testing, and the error rate of a manual process is not something they are pleased about. One particular problem is that they sometimes receive CMV antibody negative units from their blood bank supplier, even when that product has not been specifically ordered. If the product is administered to a patient who does not need a CMV antibody negative unit, they are reluctant to bill the patient according to the CMV antibody negative code; rather they want to credit the CMV serology charge. Since compliance with crediting this type of charge, and other charges is not likely to be 100%, some patients are likely to see an "over-billing" for a service that was never ordered for them.

The system that they had in place during 2003 before the implementation of these new codes was less complicated. At that time they could bill for the appropriate product and add extra charges as needed, such as for CMV antibody negativity, if the product was ordered that way.

His basic question is: Have others run into similar problems handling the new blood product codes for CMV antibody negative blood products, and if so, how is this problem being resolved?

The following comments were received.

ADDENDA Mar. 5, 2004

1. A colleague in Texas reports that they have run into a similar problem even though their laboratory information system is configured for ISBT128. All Pedi-Pak red cell units received from their supplier are CMV antibody negative. When they issue one of these products to a patient for whom CMV antibody negative red cells were not ordered, they cannot charge under the CMV antibody negative code. In summary, they cannot levy the full charge for a CMV antibody negative unless "CMV-antibody negative" is ordered.

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