AABB, America’s Blood Centers and the American Red Cross appreciate the opportunity to submit comments in response to the proposed rule updating the hospital inpatient payment system and the long-term care hospital (LTCH) payment system for 2020 (Proposed Rule). Collectively, our organizations represent the nation’s blood collection establishments, transfusion services, and transfusion medicine professionals. Our comments focus on CMS’ proposal to include a transfusion data element as part of the standardized patient assessment data elements (SPADE) for LTCHs.
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