The Advisory Committee on Blood Safety and Availability met for the
seventeenth time on September 5, 2002 at the Wyndham Washington Hotel, 1400 M
Street, N.W., Washington, D.C., 20001 to consider how government and industry
can work together to assure the availability of blood and blood products. Voting
members present were Eve Slater, Assistant Secretary for Health, Mark Brecher,
Chair, Larry Allen, Celso Bianco, Rajen Dalal, Richard Davey, Ronald Gilcher,
Edward Gomperts, Paul Haas, Keith Hoots, Dana Kuhn, Jeanne Linden, Karen Shoos
Lipton, Lola Lopes, Mark Skinner, and Jerry Winkelstein. Non-voting members
present were Jay Epstein, Col Michael Fitzpatrick, Harvey Klein. Consultants to
the Committee present were Christopher Healey and Allan Ross. Also present were
Lawrence McMurtry, Acting Executive Secretary, Virginia Wanamaker, Carolin
Commodore, Committee staff and approximately 100 members of the public.
After the roll call and reading of the conflict of interest instruction Dr.
Slater welcomed the committee and thanked them for their past and future
thoughtful consideration of the issues and assured them that their
recommendations were taken very seriously. Following her remarks Mark Skinner
told her that he was aware of the meeting she had recently had with the blood
industry and asked if such a meeting would be possible with the blood products
industry. Dr. Slater stated that his request was reasonable and Mr Skinner said
that he would be in contact with her.
Dr. Brecher then reviewed the past recommendations of the committee that were
pertinent to the current agenda. When he concluded Dana Kuhn asked to read a
statement to the committee regarding reimbursement by John Walsh who was absent.
Karen Lipton, who was scheduled to speak next, indicated that she wished to
address reimbursement issues also. The Committee agreed that after her
presentation on the Interorganizational Task Force on Domestic Disasters and
Acts of Terrorism it would turn its attention to reimbursement issues. Ms.
Lipton then reviewed the activities to date of the task force. After her
presentation on the task force Ms Lipton then asked her associate, Theresa
Wiegmann to outlined the various issues that negatively effect reimbursement and
asked the committee to recommend to the Centers for Medicare Services (CMS) that
its proposed payment rates for blood products and services be adjusted to
reflect actual costs as opposed hospital cost which are felt to be inaccurate
and out o date.
Dana Kuhn asked that Miriam O'Day be allowed to address the committee
regarding the same reimbursement issues. Ms. O'Day proceeded to review the
effect of the new CMS reimbursement rules and proposed a resolution for the
committee on the subject. After some discussion the committee decided to address
the issue of the resolution later in the morning. Mr. Kuhn agreed to draft
language for the committee to consider when it returned to the subject.
The majority of the rest of the morning was devoted to reviewing the various
blood monitoring schemes available both within the government and in the private
sector. Ginny Wanamaker reviewed the currently operating OPHS project which
receives quantitative data from 26 hospitals and 3 community blood collection
sites and explained the resulting charts and graphs. Allan Williams reviewed the
proposed Trans Net system and described how it would be a voluntary system
eventually allowing all hospitals and blood centers to report shortages. Jim
McPhearson of America's Blood Centers outlined the Stoplight system his
organization uses followed by Peter Page who described the system used by the
American Red Cross (ARC). Marian Sullivan then described the system developed by
the National Blood Data Resource Center. That system is a statistically
representative system that monitors 26 blood centers and shows that blood stocks
are virtually unchanged from last year. She also provided a very informative
talk on how her system with its extensive base line could forecast future blood
levels with varying degrees of accuracy depending on the margins of error used.
This was followed by Dan McGee a statistician from the University of Florida who
is a member of the FDA Blood Products Advisory Committee.
This was followed by a presentation by Dr. McGee who gave an overview of the
various monitoring programs and stated that monitoring was, in itself, not
sufficient. The point, he said, was not to monitor events but to look for
something unusual that occurs and to attempt to determine what caused that event
to occur and see if it could be fixed. In regard to monitoring blood stocks he
said that he believed in the shotgun approach. Dr. McGee said that there were
several disparate monitoring systems but they all indicated that there were
shortages. The conclusion he drew was that if all the systems, diverse as they
were, showed shortages then there must certainly be shortages. He also said that
of all the systems described there was only one that quantified its data
therefore it was, in his opinion, the only good system.
The following recommendation was made regarding reimbursement:
Whereas fair payment to hospitals for blood/blood components, transfusion
services, and transfusion laboratory procedures is essential to ensure that
Medicare patients have access to the best possible care;
The Advisory Committee recommends that the Secretary of Health and Human
Services direct the Centers for Medicare and Medicaid Services (CMS) to
establish 2003 Medicare hospital outpatient prospective payment system payment
rates for blood/blood components, transfusion services, and transfusion
laboratory procedures based on current-year acquisition and actual total costs
of providing such products and services, rather than on hospital outpatient
claims from previous years.
Whereas plasma derived therapies and their recombinant analogues are:
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Life sustaining or life saving treatments;
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Predominantly treating rare disorders, thereby making hospital claims data an
inadequate basis for cost analysis;
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Administered for chronic conditions therefore requiring hospitals to stock
significant supplies; and
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Administered in a hospital outpatient setting at the recommendation of health
care providers; and
Whereas the Hospital Outpatient Prospective Payment System (HOPPS) no longer
provides for adequate reimbursement of these lifesaving therapies:
The Advisory Committee recommends that the Secretary of Health and Human
Services direct the Centers for Medicare and Medicaid Services (CMS) that
payment for plasma derived therapies and their recombinant analogues be based on
current-year acquisition and actual total costs of providing such products and
services both within hospitals and in non-inpatient settings (including the
physician office) to ensure patient access to care."
Following discussion the motion was unanimously approved.
Following lunch the committee reconvened to finish with its examination of
monitoring blood stocks. Col Michael Fitzpatrick described how the Department of
Defense maintains its liquid reserves. He described the problems of frozen
reserves and that an adequate liquid reserve easily distributed to areas of need
was advantageous to the nation as a whole.
The committee then went on to consider the issue of how much blood was
enough. It heard first from Richard Counts of the Puget Sound Blood Center who
described how his center collected blood and how recruitment efforts varied
depending of projected need. He stated that his center had developed a model
that resulted in not having had severe shortages in four or five years. It was
his opinion that shortages were not so much a medical problem, but a fairly
straightforward management problem.
Gerald Sandler from Georgetown Medical Center followed with a discussion of
what an adequate inventory was for any given hospital. He said the decisions
should be driven by a proper utilization program and that using a proper program
his hospital had not experienced a cancellation of surgery in the last 10 years.
He stated that having an adequate inventory and being prepared meant that the
hospital would waste some blood though outdating a certain amount of its
stock.
Robert Jones from New York Blood Center was the next to speak. He described
how his center went from having an abundance of blood resulting from the
outpouring of donors following the events of September 11, 2002 to the severe
shortages that are resulting from the vCJD donor deferrals, the first phase of
which was scheduled for May 31, 2002. He closed by urging the FDA to examine its
donor deferral policies against the risk of a short blood supply.
Peter Page returned to tell the committee that the ARC was averaging a two to
three day inventory and that level was not sufficient to cover a catastrophic
event. There was enough blood in the ARC inventory to meet 96% of its customer
needs but that there was a great deal of volatility in distribution. He stated
that an ideal blood inventory would be a seven day supply but there would be
wastage if that level would be achieved.
Ron Gilcher of Oklahoma Blood Institute (OBI) followed and he informed the
committee that enough blood means enough to handle any major crisis and that OBI
had not imported blood into its system in over 21 years. He maintains a 17 day
blood supply and that level was moving to a 23 day supply with the addition of
frozen red cells. He said that reimbursement was a critical element of how
government and industry can work together to assure the availability of blood
and blood products.
Louis Katz was the last invited speaker and he described how the Mississippi
Valley Regional Blood Center maintained a 10 to 12 day supply at its center and
were still able to export 50% of the red blood cells it produced. He described a
social contract his center has with its population and how, through education,
they feel that giving blood is "the right thing to do."
The committee was interested in the experiences of the organ donation program
administered by the Health Services and Resources Administration . Mary Ganikos
explained how Secretary Thompson has supported the organ donation program and
how the program was enhanced by using incentives. She outlined the donor
recruitment program.
At the request of Dr. Slater the committee turned its attention to West Nile
Virus (WNV). Tony Marfin discussed efforts of the CDC to define the risk of WNV
to the population. He showed graphics that illustrated the spread of the disease
in animals and humans and showed how WNV effect the various segments of the
population. He closed by describing research in which the CDC was involved to
further define the problem.
Jessie Goodman followed with an overview of the cases of WNV confirmed to
have resulted from organ transplanted from an infected donor. He closed with a
description of the efforts the FDA was taking to prevent further spread of the
disease through blood donations.
The committee then heard from its public speakers. Roslyne Schulman of the
American Hospital
Association called for adequate reimbursement for blood and blood products.
Alan Brownstein of the American Liver Foundation called for continued vigilance
on the part of the FDA and CDC in regard to transfusion transmissible
infections. Susan Reardon of Ortho Clinical Diagnostics called for adequate
reimbursement for blood and blood products, the addition of a representative to
the committee from the CMS, the re-chartering of the committee, and the
implementation of prior recommendations. Rich Vogel of the Hemophilia Federation
of America called for continued safety. Jan Hamilton also of the Hemophilia
Federation of America thanked the committee for addressing the threat of WNV.
Dave Cavenaugh of the Committee of 10,000 called for continued monitoring of
blood supplies.
The committee then entered into discussions regarding appropriate
resolutions. After much discussion the following resolutions were
proposed:
Although the current monitoring tools have significant limitations, data from
several sources (AABB, ABC, AHA,ANRC,DHHS, and NYBC) presented at this meeting
indicate that the nation's blood inventory is currently at critical levels and
that blood shortages during the past year have resulted in postponed surgery,
and suboptimal transfusion therapy. Furthermore, to assure a ready reserve to
address potential disaster and military needs, additional blood resources will
be necessary. Therefore, the committee recommends that:
DHHS should promote increased public awareness of the ongoing need for
routine blood donations by healthy persons via
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periodic PSA's and visible blood donations by top officials and paid
advertising campaigns;
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funding of demonstrations projects to optimize use of educational and other
behavior-influencing approaches;
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supporting specific initiatives to encourage routine donations by young
persons and minorities or part of general messages on healthy life-styles and
community support;
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play a leading role in increasing participation of federal employees in
donating blood;
DHHS should maintain and/or increase funded support for blood supply
monitoring to address:
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long term trends in blood collection and use;
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data on daily nationally distributed blood inventories;
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indicators of blood shortages and excesses;
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predictive models to identify trigger points for coordinated national
donation campaigns;
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coordination of governmental and non-governmental initiatives.
DHHS should support initiatives to improve management of blood inventories
including:
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defining the role(s) of liquid and/or frozen reserves
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to moderate fluctuations in supply,
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to improve disaster response preparedness, and
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to provide backup should there be an interruption in either collecting or
testing new donations;
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integration of supply forecasting into intervention strategies directed to
correct imbalances in supply and need; and
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strategies to facilitate movement of blood from areas of surplus to areas of
shortage;
The committee shares the Departments concern regarding the possible
transmission of West Nile virus through organ donation and blood transfusion. We
commend DHHS for the rapid response to this potential public health risk and
recommend continued aggressive efforts to clarify the actual risks and the
feasibility for effective intervention.