NHIA Publishes Draft Comments to CMS on Proposed Changes to Immune Globulin HCPCS

NHIA strongly opposes CMS’s proposed HCPCS coding and billing unit changes for immune globulin products, arguing that the changes would create significant administrative, operational, reimbursement, and patient care challenges without providing meaningful clinical or financial benefit. The comments emphasize that the proposal could disrupt patient access to life-sustaining therapies, increase claim denials and compliance risks, and require extensive system updates across providers, payors, manufacturers, and pharmacies. NHIA recommends that CMS withdraw the proposal entirely or, if changes proceed, standardize billing units across products, delay implementation by at least 18 months, provide transparent rationale for the changes, and allow overlap periods and automatic prior authorization crosswalks to minimize disruption. Infusion organizations are encouraged to submit individual comments to CMS at hcpcs@cms.hhs.gov.