06/03/2026
CMS has proposed replacing the 500mg billing units used for intravenous immune globulin (IVIG) with new HCPCS codes in 100mg or 200mg units, effective January 1, 2027.
NHIA strongly opposes the proposal as these changes would impose significant operational, administrative, reimbursement, and patient care burdens across the healthcare system with no clinical benefit or cost savings to justify them. Our comments to CMS ask for the proposal to be withdrawn or, at minimum, implementation delayed 18 months, with standardized units across IG products and prior-authorization crosswalks published before any change takes effect.
Read NHIA's full comments to CMS: https://loom.ly/eRlKPS0
Home infusion providers: submit your own comments to [email protected] before the deadline.
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.