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Eye banking community breathes easier after HCFA drops plans to "bundle" payments for corneal tissue >By Jim Warren.

The Health Care Financing Administration (HCFA) has dropped plans to "bundle" payments for corneal tissue acquisition with payment to the transplant facility doing the cornea transplant. The agency's change of heart is attributed to an intensive lobbying campaign, led by the Eye Bank Association of America (EBAA), that emphasized the payment scheme could lead to the closing of eye banks and result in a significant reduction in corneal tissue procured.

HCFA had proposed that payment for the acquisition costs of corneal tissue be bundled or packaged with payment to the facility where the transplant occurred. However, the eye banking and corneal transplant community made the case that under the proposed system, the reimbursements being proposed would cover less than half of most eye bank's acquisition fees, resulting in financial shortfalls between $749 to $1,154 depending on where the transplant was performed. (Transplant News, July 16, 1999)

The EBAA and others argued that the fixed-rate payment system would be very harmful to the eye banking system and asked that the current "pass through" system of costs be retained.

HCFA finally agreed to make a lone exception and recommend that eye banking and corneal transplantation be exempt from the financing scheme "at least until further experience is gained, based on acquisition cost." Currently, payments for corneal tissue are made separately when the procedures are provided in Ambulatory Surgical Centers (ASCs) or hospital outpatient departments (HOPDs).

"I see this ruling as an exception, not a precedent," Patricia Aiken-O'Neill, EBAA president and CEO, told Transplant News. "The eye community presented a unique set of circumstances which demonstrated to HCFA convincingly that is was clearly in the best interests of the eye bank community, patients, and more importantly, HCFA, to maintain the current system. However, this represents a big victory for the eye bank and corneal transplant community."

HCFA will not publish the final rule until sometime in 2000. However, the agency has sent draft regulatory language to the congressional committees which have jurisdiction over Medicare reimbursement, explaining the corneal acquisition exception.

Both President Clinton and HCFA sent letters to congress outlining the administration's position.

In his letter to Senate Finance Committee Chairman William Roth (R-DE), Clinton wrote: "Commenters have urged that we reconsider our proposal to package payment for corneal tissue acquisition costs with that for the associated corneal transplant surgery. They believe that this fixed payment method would underpay some hospitals while overpaying others. Hospitals acquire the tissue from eye banks that charge variable rates that are strongly influenced by the amount of philanthropic contributions the bank receives in a given year. Consequently, in a significant proportion of the cases, corneal tissue is provided free or at a very low charge, while a full charge is incurred in other instances. There, if we package payment for corneal tissue, the Medicare payment would be inadequate for hospitals that are charged a full fee for the tissue but would overpay those hospitals that are not charged any fee. Commenters also were concerned that the bundled payment policy would jeopardize eye bank operations and impede beneficiary access to corneal tissue.

We believe these comments are compelling and are, therefore, likely to accept the commenters recommendations to decouple the payment for tissue acquisition from that for the surgical procedure and to pay it, at least until further experience is gained, based on acquisition cost. This approach would cover the actual cost to hospitals of tissue acquisition and avoid either underpayment or overpayment."

O'Neill pointed out that the statement "at least until further experience is gained," puts pressure on the eye banking community to demonstrate its position is sound. "This challenges the eye bank community to collect verifiable data, which can objectively warrant the continued value of the pass-through system," O'Neill wrote in an EBAA "Legislative Alert."

O'Neill credited HCFA's change of heart to the eye banking community's use of financial data instead of emotional anecdotes to explain issues.

"The EBAA was able to demonstrate to HCFA that under the current system, HCFA is a 'prudent payor' for eye banking services and is a beneficiary of the eye bank's charitable network," she wrote. "The conclusion, at least for the near future, is that all sides 'won,' as it makes sense for HCFA and for the nation's eye banks and corneal transplantation."
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Publication:Transplant News
Geographic Code:1USA
Date:Dec 10, 1999
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