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The largest single source primary payer of organ transplantation in the United States is Medicare.  The complexities of the Medicare Acquisition Cost Center can create difficulties in capturing reimbursable expenses.  Transplant programs must account for all allowable direct and indirect expenses to the appropriate Medicare Acquisition Cost Center in order to attain appropriate reimbursement through the Medicare payment system.


Medicare covers the following organ transplants:

  • Heart

  • Intestinal/Multi-Visceral (includes organs in the digestive system; stomach, duodenum, liver, and intestine).

  • Kidney

  • Lung

  • Pancreas


    Hall Consulting Services' (HSC) staff has more than 25 years of experience in providing consulting services and auditing certified organ transplant hospitals and organ procurement organizations (OPO).  Our experience encompasses the full gamut of the organ acquisition and transplant process.  The majority of that experience with organ acquisition and transplant services includes auditing, analyzing, and implementing system controls for one of the largest public healthcare systems in the nation.


    We have implemented system controls for one of the largest public healthcare systems in the nation and have recouped millions of dollars in additional reimbursement. At HCS, we offer an eight step review process for our clients.




    1. Audit of the Medicare/Medicaid Cost Report

    The Medicare/Medicaid Cost Report is the summary of all Organ Acquisition and Organ Transplants activities for a full fiscal year period.  In addition, when the Medicare/ Medicaid Cost Report is properly reviewed, organized and documented it can provide significant amounts of information which can be used to identify critical factors which will have a major impact on the reimbursement received by the Hospital or OPO.


    1. Reviewing Medicare reimbursement for organ acquisition, transplant DRGs and physician and surgeon reimbursement.


    1. Capturing all Medicare allowable expenses of a single and multi-organ Medicare approved transplant programs.


    1. Development of an “Organ Transplantation Information System” (OTIS):

  • Review critical success factors required to run a fully functional transplant information system

  • Development of a transplantation statistical system that will be based on a highly information-dependent database for the appropriate organ specialty.  All transplant programs need a well-designed software application which will become an indispensable tool for managing transplant patient care and data requirements

  • Organize an Internal Control System which will be appropriate and effective to support the hospital or OPO organ acquisition costs for single and multi-organ Medicare transplant programs

  • Audit Transplant Program accounts for all allowable direct and indirect expenses to ensure the appropriate cost allocations are made to the Medicare Organ Acquisition cost center


    1. Audit of Organ Acquisition Cost Center including the following components:              

  • Payroll expense

  • Non-salary expense

  • Direct & Indirect costs and allocations

  • Pre-transplant recipient and donor costs

  • Analysis and review of the Medicare/Medicaid cost report general ledger expenses and revenues

  • Surgeon and physician costs

  • Pre-transplant routine and ancillary service costs

  • Sq. footage/floor space

  • Excising of an organ from live and/or cadaver donor

  • Organ preservation cost

  • Transplant transportation cost


    1. Audit of Organ Acquisition Charges/Revenues and Income (Cost Recoveries):                                         

  • Audit and review transplanting hospital's “Standard Acquisition Charge (SAC) Rate(s)”

  • Review and analyze standard detail departmental charges billed to or from the transplanting hospital

  • Review complexities of the transplant multiple payor mix.

  • Develop a detail analysis of transplant patient charges to assist Medicare/Medicaid cost report allocation, classification and required revenue offsets


    1. Audit and/or Analysis of Transplant Program Drugs:

  • Audit of Medicare Part B immunosuppressive drugs following a covered transplant

  • Audit of non-immunosuppressive drugs such as antibiotics, anti-fungal medications, anti-ulcer medications, diuretics, antivirals and statins                              


    1. Medicare Billing Issues:

  • Review Medicare billing for living donor and transplant recipients

  • Review transplant program Medicare secondary payer, private payer, HMO payer and patient payments

  • Review Medicare billing for cadaver donors




    Next Service: Medicare Disproportionate Share Hospital (DSH) Analysis