July 22, 2024

Top Questions from the Organ Acquisition Principles Webinar

Looking for more information about Organ Acquisition Principles? Director of Reimbursement Software, Jeff Wolf, and BESLER Reimbursement Manager, Cody Bales, answer your questions from the recent webinar.

To watch BESLER’s Organ Acquisition Principles Webinar, click HERE.

1. 1. 1. Should OPO organs be included on the cost report based on date of procurement or receipt of payment from the OPO?
      
      The organ should be counted the day it is transferred; the payment/revenue can be handled through accounting accruals if it is made in the following FY.
    2. How do administrative SOT staff separate their time between pre and post?
      
      The Admin staff that are not interacting with patients should use the AVERAGE of the Pre/Post time from the time study of the Organ Acquisition Staff in the Organ Acquisition Department.
    3. What is a “non-certified” organ related to organs excised by the OPO in the transplant hospital?
      
      Organs excised by certified transplant centers are certified organs that may be sent to OPO.
    4. When do you become a BMT certified?
      
      Hospitals may develop BMT programs after receiving accreditation from the Foundation for the Accreditation of Cellular Therapy (FACT) or other organization granted deemed status by CMS.
    5. Is storage billable for Autologous?
      
      HSCT acquisition costs are only reimbursable for allogeneic transplants; autologous transplant costs are reimbursed under PPS.
    6. We are a children’s hospital and probably won’t have a Medicare transplant patient. Does our heart transplant program have to be approved by Medicare to be reimbursed by Medicaid?
      
      This is state specific, but in general, the answer is yes.
    7. What if you receive payment from OPO in the FY following the excision?
      
      The organ should be counted the day it is transferred; the payment/revenue can be handled through accounting accruals if it is made in the following FY.
    8. For lab services to be included in OA, would it have to on a patient’s claim?
      
      This is correct. These would be procedures that would be captured (NOT BILLED), but then the charges would be placed on WS D-4/D-6 to calculate the cost.
    9. What services typically do you include for pre-transplant services?
      
      The “Pre” services are all of the expenses incurred in Evaluating the Patient for Viability in the Transplant Program, and once accepted, all of the Maintenance services (Medical and Operational) that are necessary to maintain the patient in the ready state for the transplant procedure. Please note that the Medical services (charges) should be reviewed by a clinician to ensure that they are appropriate and related to the Maintenance of the patient for the transplant.
    10. Should you post an accrual for payments received after FY closed?
      The organ should be counted the day it is transferred; the payment/revenue can be handled through accounting accruals if it is made in the following FY.
    11. For Outpatient Charges, is it correct to include these as IP charges? Looks like if OP charges are included in D6 these are not accounted for in the flow of the cost report?
      Many of the Maintenance procedures are done on an outpatient basis. These charges should be included in WS D-4 and D-6, and the cost will be included in the Acquisition Costs.
    12. Is there any update on the prior proposed rule that might require knowing the type of insurance that the OPO recipient has?
      This rule was proposed in the FY 2022 IPPS rules. However, it was removed in the final rule. We are expecting to see this issue come back up in the future. However, we have not heard anything specific about it since.
    13. Transmedics expenses – preserve and improve viability of organ – have you seen any issue with this cost in any audits?
      These are very expensive processes; I know that CMS and the MACs are looking at them closely, but we have not seen them disallowed at this point.
    14. How is the patient’s death reported? Is it the date that the donor was placed on Life Support, or when the organ is transferred?
      The expiration of a patient would occur when the attending physician makes the call of the TOD.
    15. What is the time period of post-transplant care that is covered by DRG(IPPS)? 45 days? 90 days?
      Post-transplant care would be covered under Part B. DRG reimbursement only covers the services related to the actual transplant. The exact period of post-transplant care depends on the complications experienced after the transplant.
    16. If a kidney transplant patient has MS DRG 650 & 651, will that count for MSP?
      Yes, if all other conditions for MSP are met.
    17. For Medicare Secondary patients, do you have to bill Medicare in order to include?
      Yes.
    18. If a living donor needs a “health maintenance” service i.e. mammograph or a colonoscopy, would best practice be to bill the living donor’s insurance or bill the service to the transplant program (go on D-4 and use CCR to obtain expense)?
      If the Donor or Recipient receives Medical Care that is NOT related to the Organ Acquisition or Transplant Maintenance, these services must be billed to the Donor/Patient’s insurance. These charges should not be placed on WS D-4/D-6.
    19. For expenses, the instructions state not to reclassify costs from the routine and ancillary cost centers, but to compute the acquisition costs on Wkst D-6. Could you please clarify this item? D-6 Instructions state to use the itemized charges to complete the IP and OP Charges columns. Are the charges reported solely those BILLED under revenue code 815 or charges RELATED to the donor/recipient billed under revenue code 815?
      Medicare is trying to make sure that expenses are not counted two times for reimbursement. So, if you are performing a procedure, the charges are accounted for on WS D-4/D-6, and the costs calculated from there. If, however, there is a staff member (usually in clinics) who is helping the Recipient/Donor with scheduling, navigating UNOS, or other actions that are not billable procedures, but are related to the Organ Acquisition Process, then these will need to be reclassed to the Organ Acquisition line.
    20. Can you include organs that are excised in your hospital and sold to an OPO, but are subsequently used for Research or are discarded?
      If the organ was excised with the intent of Research, then No. If the organ was excised with the intent on Transplant, then yes, CMS did propose a change that would only allow the counting of organs that were transferred to the OPO and then transplanted into a Medicare Patient as part of the Medicare Organ Count. This proposal was removed, but we expect to see something in the future.
    21. When it comes to labs and all visits that are done on the professional side, are these allowable and reimbursable?
      As long as the labs and physician services are all related to evaluation and management of the patient for the transplant of the organ, yes.
    22. Are we allowed to include professional fees in organ acquisition costs for reimbursement?
      Yes. Physicians will be subject to the RCE limits, but otherwise they are allowable Organ Acquisition costs.
    23. Can you distinguish between Living and Deceased donor costs?
      Living Donor costs would include the evaluation (tissue typing, Cross Matching, etc.), the Maintenance (usually minor services), and the Surgical Procedure and recovery (the stay) for the excision of the Donated Organ. Deceased Donors include the evaluation and the surgical procedure to excise the organ.
    24. Can you confirm that costs and days for deceased donors should be on the cost report? How are these costs captured and the MCR D4 – Including Physician Costs?
      Yes. Hospital charges associated with a deceased donor should be collected and the days/charges included on WS D-4, Part I.
    25. Some MACs will allow you to use a different time study frequency, especially if you have hundreds of employees who would need to do the time studies. Just make sure you have it in writing from the MAC!
      Correct, but always be aware that in the end, the regulations require the time studies in a specific way.
    26. Does Medicare include Medicare Advantage when identifying the Medicare Usable Organs?
      As of 2021, ONLY for Kidney. Prior to 2021, no.
    27. Is the testing of potential donors that are not accepted reimbursable?
      Yes, this is part of the evaluation costs.
    28. Are docs Part B costs allowable?
      Yes. Physicians will be subject to the RCE limits, but otherwise they are allowable Organ Acquisition costs.
    29. Regulation states that a transplant may be counted as Medicare if a Medicare beneficiary received the organ. However, MAC refuses to count transplant as Medicare if the IPPS Claim was not paid. The regulation does not specify that the IPPS claim has to be paid, it just states that organ is transplanted into a Medicare beneficiary. What are your thoughts on this?
      We believe that the MAC would argue that since the Medicare program did not pay, then the patient was denied, and therefore Medicare has no liability. We would review the reason for the non-payment to decide what to do.
    30. For the time studies, if we do Heart transplants – is it important to make a distinction with VADs? For example, would time spent on a VAD bridge to heart transplant be allowable where time spent on a destination VAD is not allowable?
      VADs are separately billable services and therefore costs associated with them would not be considered organ acquisition costs.
    31. So phase 2 is included in the D-4?
      Yes, Services (Charges) performed during the maintenance phase related to the Organ Acquisition are allowable.
    32. We have an auditor asserting that only the evaluation is allowable. Do you have support for the maintenance time?
      Please see 42 CFR 413.402 and PRM Pt 1 Chapter 31 for allowable and non-allowable costs. It may be necessary to involve personnel with clinical knowledge to ensure the charges in question are related to the maintenance of the recipient’s condition (pre-transplant).
    33. Did I miss the response to my question regarding the support for including both evaluation and the maintenance phase?
      Please see 42 CFR 413.402 and PRM Pt 1 Chapter 31 for allowable and non-allowable costs. It may be necessary to involve personnel with clinical knowledge to ensure the charges in question are related to the maintenance of the recipient’s condition (pre-transplant).
    34. Are Medicare Advantage HSCT organs included as Medicare in the Medicare ratio on D-6?
      No, only Kidney Medicare MA patients are included in the Medicare Ratio at this time.
    35. Don’t the three months after donation count as OA?
      All services prior to donation and deceased donor excisions are considered organ acquisition costs. Post transplant services are covered under Part B unless the donor or recipient are re-admitted and are not considered organ acquisition costs except for living donors of non-renal organs. Post-transplant complication costs to living donors of non-renal organs are considered organ acquisition costs.
    36. How long after donation is the donor covered?
      That would depend on the complications experienced.
    37. How should administrative time be allocated between pre and post? Example studying the financial, interviewing candidates, human resource functions.
      The Admin staff who are not interacting with patients should use the AVERAGE of the Pre/Post time from the time study of the Organ Acquisition Staff in the Organ Acquisition Department.
    38. If I am waiting for a Heart Transplant, and need a VAD. Is that a maintenance expense?
      VAD is a separately billable item related to the life of the recipient and is not considered a maintenance item for organ acquisition.
    39. What happens with the cost of unusable organs?
      The cost of Acquiring them is still part of the Organ Acquisition process, but reimbursement will be only partial due to the application of the Medicare Ratio.
    40. Can facilities pursue recoveries for BMT similarly to Solid Organs with the D6 Information?
      Yes, the HSCT acquisition services that we discussed may be prepared and reported on the new WS D-6, and the reimbursement received would be in addition to the DRG payment received for the transplant itself.
    41. If paid at the DRG?
      Yes, the HSCT acquisition services that we discussed may be prepared and reported on the new WS D-6, and the reimbursement received would be in addition to the DRG payment received for the transplant itself.
    42. Having audio issues, are the number of hearts that are transplanted into Medicare Advantage patients included in the total Medicare number of organs or no?
      No – at this time, only kidneys may be counted for MA beneficiaries
    43. Can you confirm that organs transplanted into Medicare Advantage patients also go into the total Medicare # of organs?
      As of 2021, ONLY for Kidney. Prior to 2021 no.
    44. When computing the amount of revenue from organs sold to OPO, can we count organs that ended up being sent for research but the original intent of harvesting the organ was to transplant?
      If the organ was excised with the intent of Research, then No. If the organ was excised with the intent on Transplant, then yes, CMS did propose a change that would only allow the counting of Organs that were transferred to the OPO, and then transplanted into a Medicare Patient as part of the Medicare Organ Count. This proposal was removed, but we expect to see something in the future.
    45. If a donor is readmitted at a future date due to donor complications, can we count charges associated with that readmission?
      The re-admission would be charged to the recipient’s account and not considered organ acquisition unless the patient is a donor of a non-renal organ, in which case would be considered organ acquisition costs.