AABB, America’s Blood Centers and the American Red Cross welcome the opportunity to submit comments to the Centers for Medicare & Medicaid Services (CMS) in response to the proposed rule related to the hospital outpatient prospective payment system (OPPS) published in the Federal Register on August 9, 2019. Collectively, our organizations represent the nation’s blood collection establishments, transfusion services, and transfusion medicine professionals. Our comments focus on CMS’ proposals related to the laboratory date of service (DOS) policy as well as reimbursement for blood products.
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