Breyanzi (lisocabtagene maraleucel) — HCPCS Q2054

Bristol-Myers Squibb (Juno Therapeutics) · Autologous anti-CD19 CAR-T with defined 1:1 CD8:CD4 composition · Single IV infusion at a FACT-accredited center · First CAR-T approved in CLL/SLL (TRANSCEND CLL 004, March 14, 2024) and first CAR-T approved in MZL (December 4, 2025)

Breyanzi is the BMS/Juno anti-CD19 CAR-T product with the broadest indication footprint in the CD19 class: LBCL (2L and 3L+), CLL/SLL, follicular lymphoma, mantle cell lymphoma, and (as of December 4, 2025) marginal zone lymphoma. It is manufactured to a defined 1:1 CD8:CD4 ratio — two separately enriched bags infused sequentially — using a 4-1BB costimulatory domain, which together deliver the lowest Grade 3+ CRS profile in the CD19 CAR-T class (typically less than 5%). The Q2054 single-dose code sits at the center of a five-stage encounter: leukapheresis, ~24-35 day manufacturing (longer than Yescarta due to the dual CD8 / CD4 process), lymphodepleting chemotherapy, sequential two-bag CAR-T infusion, and CRS/ICANS monitoring. Administration is restricted to FACT-accredited centers certified under the BREYANZI REMS, with patient support through the BMS Cell Therapy 360 hub. Breyanzi runs the highest share of outpatient infusion in the CD19 class. Q2 2026 Medicare payment limit per single dose: $562,260.836.

ASP data:Q2 2026 (live)
Payer policies:verified May 2026
IPPS/OPPS rules:FY 2026 Final Rule
FDA label:most recent rev
Page reviewed:

Instant Answer — the 5 things you need to bill Q2054

HCPCS
Q2054
1 unit = 1 dose
Therapeutic dose
1 unit
2 sequential bags (CD8 + CD4)
Setting
MS-DRG 018
FACT-accredited; outpatient APC common
Admin CPT
0537T–0541T
Cat III CAR-T administration set
Medicare ASP+6%
$562,260.836
per single dose, Q2 2026
HCPCS descriptor
Q2054 — "Lisocabtagene maraleucel, up to 110 million autologous anti-CD19 CAR positive viable T cells, including leukapheresis and dose preparation procedures, per therapeutic dose" Permanent — note the 110M cell count vs Yescarta/Tecartus 200M, reflecting the defined-composition manufacturing
Indications (FDA)
(1) Adult R/R LBCL after ≥ 2 prior lines incl. DLBCL NOS, high-grade B-cell lymphoma, PMBCL, FL grade 3B — approved Feb 5, 2021 (TRANSCEND NHL 001); (2) 2L R/R LBCL — primary refractory or relapse within 12 months — approved Jun 24, 2022 (TRANSFORM); (3) R/R CLL/SLL after ≥ 2 prior lines incl. BTKi + BCL-2i — first-ever CAR-T in CLL/SLL, accelerated approval Mar 14, 2024 (TRANSCEND CLL 004); (4) R/R FL after ≥ 2 prior lines — May 15, 2024 (TRANSCEND FL); (5) R/R MCL after BTKi — May 30, 2024; (6) R/R marginal zone lymphoma (MZL) after ≥ 2 prior lines — first CAR-T in MZL, approved Dec 4, 2025 (TRANSCEND FL-MZL cohort, NCT04245839)
NDC
Patient-specific lot. Manufacturer carton NDC pattern: 73154-001-XX (Juno Therapeutics / BMS labeler 73154) for the cell product bags; verify the actual lot/NDC on the chain-of-identity label shipped with the patient's dose. Both the CD8 and CD4 component bags share the same NDC pattern with bag-specific identifiers.
Cellular product
Two-bag single-dose IV infusion: autologous CD19 CAR-T cells manufactured to a defined 1:1 CD8:CD4 composition with a 4-1BB costimulatory domain. CD8 component infused first, then CD4 component minutes later. Target dose: up to 110 x 10^6 CAR-positive viable T cells per therapeutic dose (lower total than Yescarta/Tecartus's 200M cap, reflecting the higher cellular potency of the defined composition).
Lymphodepletion
Required, days -5 to -3: fludarabine 30 mg/m^2/day (J9185) + cyclophosphamide 300 mg/m^2/day (J9070) per FDA label. Note the lower cyclophosphamide dose (300 vs 500 mg/m^2 for Yescarta). Separately billable.
Boxed warning
Cytokine Release Syndrome (CRS) · Neurologic Toxicity / ICANS · Prolonged Cytopenias · Secondary Malignancies (T-cell) — CRS Grade 3+ rate is the lowest in CD19 CAR-T class (typically < 5%) but still requires tocilizumab (Actemra J3262) immediately available
REMS
BREYANZI REMS required — only FACT-accredited centers certified by BMS can dispense and administer; prescriber + facility + pharmacy certification. Separate from Kite YESCARTA/TECARTUS REMS — manufacturer-specific certifications do not cross-recognize.
Pivotal trials
TRANSCEND NHL 001 (3L+ LBCL — Abramson Lancet 2020); TRANSFORM (2L LBCL — Kamdar Lancet 2022); TRANSCEND CLL 004 (first CAR-T in CLL/SLL — Siddiqi Lancet 2023); TRANSCEND FL (R/R FL, May 2024); MCL approval supplement (May 2024); TRANSCEND FL-MZL cohort (R/R MZL, NCT04245839 — basis of Dec 4, 2025 approval)
⚠️
FACT accreditation + BREYANZI REMS certification gate every Q2054 claim. Sites that administer Breyanzi without both will be denied at adjudication, paid claims recouped, and may face FDA reporting. A center that is certified for Yescarta or Tecartus (Kite products) is NOT automatically certified for Breyanzi — BMS administers its own REMS independent of Kite's. Verify BMS BREYANZI certification and FACT/FACT-JACIE accreditation BEFORE scheduling apheresis. See REMS section and CD19 CAR-T class comparison.

The 5-stage Breyanzi workflow at a glance

  1. Apheresis — 38206 / 0540T at FACT center
  2. Manufacture — ~24-35 day wait; separate CD8 / CD4 enrichment + transduce
  3. Lymphodeplete — flu (J9185) + cy (J9070); 30/300 mg/m^2 days -5 to -3
  4. CAR-T infusion — Q2054 + 0537T-0541T; CD8 bag then CD4 bag
  5. CRS / ICANS — lowest rates in class; outpatient pathway common
Phase 1 Identify what you're billing CAR-T is a multi-stage encounter, not a single claim. Map the workflow first.

About Breyanzi (lisocabtagene maraleucel)

Breyanzi is the brand name for lisocabtagene maraleucel (liso-cel), an autologous chimeric antigen receptor (CAR) T-cell immunotherapy directed against the CD19 antigen, manufactured by Bristol-Myers Squibb (originally developed by Juno Therapeutics, acquired by Celgene in 2018, then BMS in 2019). It is the fourth FDA-approved CAR-T cell therapy (February 5, 2021) and carries the broadest CD19 indication footprint of any CAR-T: LBCL at both 3L+ and 2L, CLL/SLL (the first CAR-T ever approved in this disease), follicular lymphoma, mantle cell lymphoma, and — as of December 4, 2025 — marginal zone lymphoma (also a first-in-class CAR-T approval).

Each Breyanzi dose is a patient-specific cellular product manufactured to a defined 1:1 CD8:CD4 composition. The patient's T cells are collected by leukapheresis, shipped to the BMS cell-therapy manufacturing facility, separated into CD8+ and CD4+ subsets, separately transduced with the anti-CD19 CAR construct (using a 4-1BB costimulatory domain), expanded, formulated into two distinct bags at a 1:1 ratio, cryopreserved, and shipped back to the certified treatment center for sequential infusion. Breyanzi's vein-to-vein time is approximately 24-35 days, the longest in the CD19 CAR-T class because of the separate CD8 / CD4 processing.

Breyanzi carries six FDA-approved indications:

  • Adult relapsed/refractory large B-cell lymphoma (3L+) after at least two prior lines of systemic therapy, including DLBCL NOS, high-grade B-cell lymphoma, primary mediastinal large B-cell lymphoma (PMBCL), and follicular lymphoma grade 3B — approved February 5, 2021 based on the TRANSCEND NHL 001 trial.
  • Adult relapsed/refractory large B-cell lymphoma in the second-line setting — primary refractory or relapse within 12 months of first-line chemoimmunotherapy — approved June 24, 2022 based on the TRANSFORM trial.
  • Adult relapsed/refractory chronic lymphocytic leukemia (CLL) or small lymphocytic lymphoma (SLL) after at least two prior lines including a BTK inhibitor and a BCL-2 inhibitor — accelerated approval March 14, 2024 based on the TRANSCEND CLL 004 trial. This is the first and only CAR-T approved in CLL/SLL.
  • Adult relapsed/refractory follicular lymphoma (FL) after at least two prior lines of systemic therapy — accelerated approval May 15, 2024 based on the TRANSCEND FL trial.
  • Adult relapsed/refractory mantle cell lymphoma (MCL) after BTK inhibitor therapy — approved May 30, 2024 based on supplementary TRANSCEND MCL data.
  • Adult relapsed/refractory marginal zone lymphoma (MZL) after at least two prior lines of systemic therapy — approved December 4, 2025 based on the TRANSCEND FL-MZL cohort (NCT04245839). This is the first CAR-T approved in MZL and extends Breyanzi's CD19 footprint to six lymphoma histologies — the broadest of any CAR-T product.

Breyanzi is billed under HCPCS Q2054 as a single therapeutic dose. The HCPCS descriptor explicitly bundles the leukapheresis and dose preparation procedures into the Q-code, though most payers and CMS still permit separate billing of the apheresis CPT and lymphodepletion drugs in practice. Administration is restricted to FACT-accredited centers certified under the BREYANZI REMS program (administered by BMS, separate from Kite's YESCARTA and TECARTUS REMS). Approximate list price (single dose): ~$447,000 USD.

CD19 CAR-T class — Breyanzi vs Yescarta vs Kymriah vs Tecartus FDA + payer review May 2026

Four anti-CD19 CAR-T products exist, plus two BCMA-targeted CAR-T products for myeloma. Coding and PA logic are not interchangeable.

ProductGenericHCPCSTargetPrimary indicationsManufacturer
Breyanzilisocabtagene maraleucelQ2054CD19 (4-1BB costim, 1:1 CD8:CD4)R/R LBCL (2L+), CLL/SLL, FL, MCL, MZL — broadest CD19 footprintBMS / Juno
Yescartaaxicabtagene ciloleucelQ2041CD19 (CD28 costim)R/R DLBCL/LBCL (2L+ & 3L+), R/R FLKite / Gilead
KymriahtisagenlecleucelQ2042CD19 (4-1BB costim)Peds/young adult ALL (≤25), R/R DLBCL, R/R FLNovartis
Tecartusbrexucabtagene autoleucelQ2053CD19 (CD28 costim) + T-cell enrichmentR/R MCL (post-BTKi), adult R/R B-ALLKite / Gilead
Different target class — BCMA CAR-T for myeloma (NOT CD19):
Abecmaidecabtagene vicleucelQ2055BCMAR/R multiple myeloma (3L+)BMS
Carvykticiltacabtagene autoleucelQ2056BCMAR/R multiple myeloma (1L+ as of 2024)Janssen / Legend
Do not substitute Q-codes. Each CAR-T product has its own Q-code, REMS program, and FACT certification. A claim submitted with the wrong Q-code will be denied even if every other field is correct. The chain-of-identity label on the patient's cellular product is the authoritative source for which Q-code to bill. Breyanzi carton NDCs use BMS labeler 73154; Kite Q2041/Q2053 use labeler 71287; Novartis Q2042 uses its own labeler. Note that Q2054 is the only CD19 Q-code with a 110-million cell-count basis (vs 200M for Yescarta and Tecartus) — the smaller descriptor reflects Breyanzi's defined 1:1 composition, not a lower dose strength.
When Breyanzi is the typical choice over other CD19 CAR-T: (1) R/R CLL/SLL after BTKi + BCL-2i failure — Breyanzi is the only CAR-T approved in this disease; (2) any LBCL patient where outpatient infusion is desired and CRS toxicity must be minimized — Breyanzi consistently posts the lowest Grade 3+ CRS rate in the CD19 class (typically less than 5%); (3) elderly or comorbid LBCL patients where the CD28-driven CRS spike of Yescarta would be operationally difficult to manage; (4) 2L LBCL when manufacturing turnaround can absorb the longer Breyanzi vein-to-vein. Yescarta is preferred when speed-to-infusion is critical (high tumor burden, rapid progression). For peds ALL use Kymriah; for adult B-ALL use Tecartus; for MCL, both Tecartus and Breyanzi are options.
CD28 vs 4-1BB costimulatory domain — and why it matters for Breyanzi. Breyanzi and Kymriah use a 4-1BB costimulatory domain; Yescarta and Tecartus use CD28. 4-1BB generally drives slower, more controlled T-cell expansion with longer persistence and lower peak CRS / ICANS; CD28 drives faster, more potent expansion with higher early-peak CRS. This is the principal pharmacological reason Breyanzi consistently posts the lowest Grade 3+ CRS rate among CD19 CAR-T products (TRANSCEND NHL 001: ~2%; TRANSFORM: ~1%; TRANSCEND CLL 004: ~9% in a higher-burden population) — an operational advantage for outpatient pathway approval and ICU stewardship.
The defined 1:1 CD8:CD4 composition. Breyanzi is unique in the CAR-T class for being manufactured to a defined 1:1 ratio of CD8+ cytotoxic and CD4+ helper CAR-T cells, formulated into two separate infusion bags that are administered sequentially (CD8 first, then CD4 minutes later). Yescarta, Tecartus, and Kymriah are unfractionated single-bag products. The clinical hypothesis behind the defined composition is that the 1:1 ratio reduces inter-patient variability in CAR-T pharmacodynamics and suppresses runaway CRS. Operationally, this means: the cellular product ships as two distinct bags with bag-specific COI labels; the infusion service captures two sequential administrations; and pharmacy must not pre-mix the bags. Quality-check the bag identity before each sequential infusion.

The 5-stage CAR-T workflow FDA label + REMS verified May 2026

CAR-T billing is fundamentally different from standard drug billing because the encounter spans 4-6+ weeks across multiple claims. Breyanzi's longer manufacturing extends the window.

Stage 1
Apheresis
38205 / 38206 / 0540T
Autologous T-cell collection at a FACT-accredited apheresis center. Single 3-5 hour session, usually outpatient.
Stage 2
Manufacturing
No billing
~24-35 day wait (longest in CD19 class). Cells shipped to BMS facility for separate CD8 / CD4 enrichment, CAR transduction (4-1BB costim), separate expansion, formulation to 1:1, cryopreservation.
Stage 3
Lymphodepletion
J9185 + J9070
Days -5 to -3: fludarabine 30 mg/m^2 + cyclophosphamide 300 mg/m^2 (note lower cy dose vs Yescarta's 500). Outpatient or inpatient.
Stage 4
CAR-T infusion
Q2054 + 0537T-0541T
Day 0. Two sequential bags (CD8 then CD4) at certified center. Inpatient MS-DRG 018 OR outpatient OPPS APC — Breyanzi has the highest outpatient share in CD19 class.
Stage 5
CRS / ICANS
Tocilizumab J3262
Day +1 to +28+. Lowest rates in CD19 class: CRS ~40-50% any-grade, <5% Grade 3+; ICANS ~20-30% any-grade. Readmission less common than Yescarta/Tecartus.

Typical claim cadence

  1. Claim A — Apheresis encounter: CMS-1500 or UB-04 with 38206 (or 0540T) + supporting ICD-10. Often paid as outpatient hospital service or office procedure.
  2. Claim B — Lymphodepletion encounter(s): J9185 + J9070 with admin CPTs 96409/96413/96415 as appropriate. May span 3 outpatient visits or one short admission.
  3. Claim C — CAR-T admission or outpatient infusion: Inpatient: UB-04 with ICD-10-PCS procedure (XW033C3 or XW043C3) driving MS-DRG 018. Q2054 line-item is included in the DRG bundle. Outpatient (common for Breyanzi): UB-04 outpatient with APC payment + Q2054 + 0537T-0541T line items.
  4. Claim D — CRS/ICANS readmission (if applicable): Inpatient DRG based on principal manifestation (sepsis, respiratory failure, encephalopathy) with tocilizumab and supportive care billed within the DRG. Operationally less frequent for Breyanzi than for CD28-domain products.

Dosing & cellular dose math FDA label verified May 2026

Breyanzi is one therapeutic dose, but the dose is delivered as two sequential bags at a defined 1:1 CD8:CD4 ratio with a total cap of 110 million CAR-positive T cells.

IndicationPatient populationTarget dose (per FDA label)Bill
R/R LBCL (3L+ and 2L)Adult, ≥2 prior lines OR primary refractory / early-relapse50-110 x 10^6 CAR+ viable T cells total (1:1 CD8:CD4, two bags)1 unit of Q2054
R/R CLL/SLLAdult, ≥2 prior lines incl. BTKi + BCL-2i90-110 x 10^6 CAR+ viable T cells total (1:1, two bags)1 unit of Q2054
R/R FLAdult, ≥2 prior lines50-110 x 10^6 CAR+ viable T cells total (1:1, two bags)1 unit of Q2054
R/R MCLAdult, post-BTKi50-110 x 10^6 CAR+ viable T cells total (1:1, two bags)1 unit of Q2054
Q2054 is billed as one therapeutic dose regardless of the two-bag administration. The two component bags (CD8 + CD4) are part of one therapeutic dose under the HCPCS descriptor. Do not bill two units of Q2054. The chain-of-identity labels on each of the two bags document the CD8 and CD4 component cell counts; the Certificate of Analysis (COA) shipped with the cellular product confirms the 1:1 ratio and total viable cell count. Only one billable unit goes on the claim. Note the descriptor cell count basis (110 million) is lower than Yescarta/Tecartus (200 million) — this reflects the defined-composition formulation and the higher per-cell potency, not a lower-strength product.

Lymphodepletion dosing (Stage 3) — uniform across indications

Per the FDA Breyanzi label, the lymphodepletion regimen is the same regardless of indication: fludarabine 30 mg/m^2 IV daily x 3 days (J9185) plus cyclophosphamide 300 mg/m^2 IV daily x 3 days (J9070), days -5 to -3. Note the lower cyclophosphamide dose vs Yescarta's 500 mg/m^2 and Tecartus MCL's 500 mg/m^2. The lower cyclophosphamide dose contributes to Breyanzi's better post-infusion cytopenia profile and supports outpatient feasibility. CAR-T cell infusion proceeds on day 0 (2-7 days after the last lymphodepletion dose).

# Adult, 1.85 m^2 BSA, 70 kg, R/R DLBCL post-R-CHOP post-salvage receiving full Breyanzi sequence (3L+ LBCL)

# Stage 1 (apheresis):
CPT 38206 (autologous hematopoietic harvesting) x 1
ICD-10-PCS 6A550Z2 (apheresis, leukapheresis, single)

# Stage 3 (lymphodepletion, days -5 to -3):
Fludarabine 30 mg/m^2 = 55.5 mg/day x 3 days = 167 mg total
Bill: J9185 167 units (1 mg = 1 unit) across 3 dates of service
Cyclophosphamide 300 mg/m^2 = 555 mg/day x 3 days = 1665 mg total
Bill: J9070 ~17 units total (per 100 mg unit basis, ~5.6 units/day x 3)
Admin: 96413 + 96415 per infusion day

# Stage 4 (CAR-T infusion, day 0):
Target: 50-110 x 10^6 total CAR+ T cells, formulated 1:1 CD8:CD4
Bill: Q2054 1 unit (covers both bags)
Admin CPTs: 0537T (planning), 0538T (prep for transport), 0539T (receipt+prep), 0540T (administration), 0541T (preparation)
Inpatient option: MS-DRG 018, ICD-10-PCS XW033C3 (CAR-T, peripheral vein)
Outpatient option (common for Breyanzi): OPPS APC + Q2054 + 0537T-0541T line items

# Stage 5 (monitoring +/- readmit, <5% Grade 3+ CRS):
Tocilizumab (Actemra) J3262 at 8 mg/kg IV per CRS dose if Grade 2+ develops
Bundled in DRG 018 if inpatient; line-item billable in outpatient pathway
# Adult, 68 yr old, 75 kg, R/R CLL post-ibrutinib-then-venetoclax receiving Breyanzi (TRANSCEND CLL 004 indication)

# PA eligibility gate:
Must document prior BTKi (ibrutinib, acalabrutinib, or zanubrutinib) failure dates & reason
AND prior BCL-2 inhibitor (venetoclax) failure dates & reason
Diagnosis code: C91.10 CLL of B-cell type, not having achieved remission

# Stage 3 (lymphodepletion, days -5 to -3, same regimen as LBCL):
Fludarabine 30 mg/m^2 = 53 mg/day x 3 = 160 mg, J9185 160 units
Cyclophosphamide 300 mg/m^2 = 530 mg/day x 3, J9070 ~17 units

# Stage 4 (CAR-T infusion):
Target: 90-110 x 10^6 total CAR+ T cells (CLL/SLL dose range narrower than LBCL)
Bill: Q2054 1 unit with diagnosis C91.10 or C83.0x (SLL)
FIRST AND ONLY CAR-T approved in CLL/SLL — cite TRANSCEND CLL 004 + NCCN CLL Guidelines in PA narrative for policy-lagging payers

NDC reference FDA NDC Directory + BMS verified May 2026

Breyanzi uses a patient-specific NDC pattern - every patient's dose is uniquely identified by lot, AND the CD8 and CD4 component bags have bag-specific identifiers within the same NDC family.

NDCStrengthPackage SizeUnits/Vial
73154-001-XX (Juno/BMS labeler 73154; XX = patient-specific lot/component suffix) Up to 110 x 10^6 CAR+ viable T cells total (1:1 CD8:CD4) Two cryopreserved infusion bags (CD8 component + CD4 component), patient-specific 1 unit of Q2054 (= 1 therapeutic dose covering both bags)
Two-bag NDC pattern. Breyanzi ships as two distinct cryopreserved bags — one CD8 component, one CD4 component — each labeled with the same carton-level NDC family (73154-001-XX) but with bag-specific component identifiers and chain-of-identity tags. The N4 NDC field on the claim carries one NDC representing the therapeutic dose; the bag-specific COI is documented in the chart and is verified by the pharmacy before each of the two sequential infusions. Confirm both COI tags match the patient at chair-side before infusing each bag.
Why this matters for billing: Some payer claim-adjudication systems will not validate a CAR-T NDC against their formulary master file because the lot-specific NDC may not appear in static reference data. If you receive an automated NDC-not-found denial, escalate to the medical drug review queue and reference the BMS chain-of-identity documentation. BMS Cell Therapy 360 (the Breyanzi patient hub) can supply documentation directly to payer escalation queues.

BREYANZI REMS + FACT accreditation BMS + FACT verified May 2026

Breyanzi is available only through a restricted REMS program because of the boxed warnings for CRS, neurologic toxicity, prolonged cytopenias, and secondary T-cell malignancies.

The BREYANZI REMS is administered by Bristol-Myers Squibb and operates as closed distribution. Three certification layers must all be in place:

  • Facility certification (BMS Authorized Treatment Center): the hospital or cellular therapy center must be on the BMS-maintained list of authorized Breyanzi Treatment Centers. Certification requires FACT or FACT-JACIE accreditation for cellular therapy, demonstrated capacity to recognize and manage CRS and ICANS (even though Breyanzi's profile is the lowest in class), immediate availability of tocilizumab (Actemra) for IV use, and qualified ICU backup. Outpatient-capable centers additionally certify their post-infusion ambulatory monitoring protocols with BMS.
  • Healthcare provider certification: prescribing physicians must complete the BREYANZI REMS training and be enrolled.
  • Pharmacy / chain-of-custody certification: the receiving pharmacy and cellular therapy lab must verify physician + facility certification before accepting the patient-specific cellular product. The two-bag receipt protocol must be in place to handle CD8 and CD4 components separately.

How to enroll / verify

  • Web: BMS maintains the BREYANZI REMS portal — check the most recent Breyanzi Prescribing Information for the current REMS URL and contact. BMS Cell Therapy 360 (the patient hub, shared with Abecma) can route facility questions to the REMS team.
  • FACT accreditation: factwebsite.org — verify accreditation status of any center before referral.
  • Documentation: retain REMS enrollment confirmation in the patient chart and on every PA submission. Submit FACT accreditation certificate as a PA attachment.
Common error: Kite (Yescarta/Tecartus) certification does not extend to Breyanzi. A center that is FACT-accredited and Kite-certified for Yescarta or Tecartus is NOT automatically certified for Breyanzi. BMS administers the BREYANZI REMS independently and has its own treatment center qualification cycle. The most common operational failure is assuming Kite certification covers Breyanzi — it does not. Confirm BOTH FACT accreditation AND BMS Breyanzi certification (independent of any Kite or Novartis certification) for the apheresis facility, the manufacturing chain, and the infusion facility before scheduling Stage 1.
Phase 2 Code the claim (each stage has its own) Apheresis, lymphodepletion, CAR-T infusion, and CRS readmission each generate distinct claims with distinct logic.

Administration codes — the multi-stage code set CPT 2026 verified May 2026

Each of the 5 stages has its own administration code family. Map them to the correct claim.

Stage 1 - Apheresis

CodeDescriptionWhen to use
38206Blood-derived hematopoietic progenitor cell harvesting for transplantation, per collection; autologousMost common code for CAR-T leukapheresis at most centers; broadly accepted by MACs and major commercial payers.
38205Blood-derived hematopoietic progenitor cell harvesting for transplantation, per collection; allogeneicNOT applicable to autologous CAR-T. Listed here for disambiguation only.
0540TInsertion of central venous catheter for therapeutic apheresis (Category III, CAR-T-specific)Required by some commercial payers for CAR-T-specific apheresis service capture. Verify per-payer.
36511Therapeutic apheresis; for white blood cellsSome legacy payer policies prefer this code for the apheresis service itself. Verify.

Stage 3 - Lymphodepletion (chemo admin)

CodeDescription
96413Chemotherapy administration, IV infusion technique; up to 1 hour, single or initial substance/drug
96415each additional hour (List separately in addition to code for primary procedure)
96417each additional sequential infusion (different substance/drug), up to 1 hour
96409Chemotherapy administration; IV push, single or initial substance/drug

Stage 4 - CAR-T infusion administration set

CodeDescriptionWhen to use
0537TChimeric antigen receptor T-cell (CAR-T) therapy; harvesting of blood-derived T lymphocytes for development of genetically modified autologous CAR-T cells, per day (Category III)Planning / pre-collection encounter at the CAR-T center.
0538TCAR-T therapy; preparation of blood-derived T lymphocytes for transportation (Category III)Cell preparation and shipping service.
0539TCAR-T therapy; receipt and preparation of CAR-T cells for administration (Category III)Receipt of returned product and prep for infusion. For Breyanzi: receipt of two bags (CD8 + CD4).
0540TCAR-T therapy; CAR-T cell administration, autologous (Category III)The infusion service itself. Bill on the day of Q2054 infusion. The two sequential bags (CD8 then CD4) constitute one administration service.
0541TCAR-T therapy; preparation of CAR-T product (Category III)Pre-infusion preparation of the cellular product for administration.
96365 / 96413Standard IV infusion / chemo administration codesNOT appropriate. CAR-T cellular product infusion is a distinct service from standard drug infusion.
Category III status as of CPT 2026. The 0537T-0541T family remains Category III (emerging technology). AMA may transition these to Category I in a future revision. Always check the current AMA CPT release for code status changes - if Category I codes have been issued, payer adjudication logic shifts accordingly. Some payers reimburse 0537T-0541T at a fixed-fee or invoice-priced rate; others bundle into MS-DRG 018 for inpatient claims. The two-bag Breyanzi administration does NOT generate two 0540T claims — the sequential infusion is one CAR-T administration service.

Stage 5 - CRS / ICANS management

Tocilizumab (Actemra, HCPCS J3262) is the FDA-approved CRS treatment. Dose for CRS: 8 mg/kg IV (max 800 mg), up to 4 doses. Bill J3262 with appropriate IV infusion admin code (96365). When CRS occurs during the inpatient CAR-T admission, tocilizumab is bundled in MS-DRG 018; when administered outpatient or during a separate readmission, bill J3262 line-item against the relevant ICD-10 (D89.83x for CRS - see ICD-10 section). Breyanzi's class-low CRS profile (typically < 5% Grade 3+) means tocilizumab use is operationally lower than with CD28-domain products. Pharmacy still must maintain on-hand minimums per REMS.

Modifiers CMS + CPT verified May 2026

Modifiers rarely apply to Q2054 itself

Unlike weight-based drug J-codes, the single-dose Q2054 code does not generate JW (drug waste) or JZ (no-waste single-dose container) reporting in most circumstances. The cellular product is one patient-specific therapeutic dose - it is either administered in its entirety to the labeled patient or the manufacturing fails and the product is not infused (in which case Q2054 is not billed). There is no partial-vial waste scenario analogous to small-molecule oncology drugs.

Some MACs still require JZ. Per the July 1, 2023 CMS single-dose container policy, a few MACs have interpreted Q2054 as a single-dose container subject to JZ when no waste occurs. Most do not. Check your MAC's article on JW/JZ applicability to cellular products before suppressing or adding the modifier. The two-bag nature of Breyanzi does not change the modifier logic — one therapeutic dose is one billable unit.

Modifier 25 - same-day E/M

Use modifier 25 on the E/M code when a significant, separately identifiable evaluation and management service is performed on the same day as a CAR-T-related procedure. Pre-infusion clinical assessment is bundled; a same-day workup for a new complication is separately reportable with 25.

340B modifiers (JG, TB)

Most CAR-T treatment centers are 340B-covered entities. For 340B-acquired Q2054, follow your MAC's current 340B modifier policy (JG or TB as required). BMS CAR-T 340B and OPPS/IPPS payment interaction is jurisdiction-specific - verify with your 340B compliance team.

Modifiers on lymphodepletion (Stage 3)

Lymphodepletion uses standard chemotherapy modifier rules - JW on partial-vial waste for fludarabine and cyclophosphamide as needed; JZ when no waste. These follow the standard J9185 and J9070 modifier logic and are unrelated to Q2054 billing. Breyanzi's lower 300 mg/m^2 cyclophosphamide dose makes partial-vial residuals slightly more common than at Yescarta's 500 mg/m^2.

ICD-10-CM & ICD-10-PCS coding FY2026 verified May 2026

Two coding systems matter: ICD-10-CM for diagnosis (every claim), ICD-10-PCS for the CAR-T procedure (inpatient only - drives MS-DRG 018).

ICD-10-CM diagnoses

IndicationCodeDescription
LBCL / DLBCL (3L+ & 2L)C83.30 - C83.39Diffuse large B-cell lymphoma, by site
C85.20 - C85.29Mediastinal (thymic) large B-cell lymphoma (PMBCL)
C83.50 - C83.59Lymphoblastic (diffuse) lymphoma / high-grade B-cell lymphoma (HGBL)
CLL / SLL (NEW indication, March 2024)C91.10 - C91.12Chronic lymphocytic leukemia of B-cell type (in remission, in relapse, NOS)
C83.00 - C83.09Small cell B-cell lymphoma (SLL)
Follicular lymphoma (FL)C82.0x - C82.9xFollicular lymphoma, by grade and site
chart narrativeDocument ≥2 prior lines incl. anti-CD20 mAb + alkylator
Mantle cell lymphoma (MCL)C83.10 - C83.19Mantle cell lymphoma, by site. PA narrative must document prior BTKi failure.
BTKi + BCL-2i failure (CLL/SLL)chart narrative + Z79.899Document prior BTK inhibitor exposure (ibrutinib / acalabrutinib / zanubrutinib) AND prior BCL-2 inhibitor (venetoclax): start dates, stop dates, reason (progression vs intolerance) for each.
Timing of 2L relapse (LBCL)chart narrativeFor 2L LBCL: explicit documentation of "primary refractory" OR "relapse within 12 months of first-line chemoimmunotherapy"
Post-HSCTZ94.81Bone marrow transplant status (use when CAR-T follows prior HSCT)
CRSD89.831 - D89.835Cytokine Release Syndrome, by grade (D89.831 = G1, D89.832 = G2, D89.833 = G3, D89.834 = G4, D89.835 = G5)
ICANSG92.0xImmune effector cell-associated neurotoxicity syndrome (new code family, FY 2023+)

ICD-10-PCS procedures (inpatient claims)

CodeDescriptionUse
XW033C3Introduction of engineered autologous chimeric antigen receptor T-cell immunotherapy into peripheral vein, percutaneous approach, new technology group 3The primary PCS code that drives MS-DRG 018 for peripheral IV CAR-T administration.
XW043C3Introduction of engineered autologous CAR-T immunotherapy into central vein, percutaneous approach, new technology group 3For central-line CAR-T administration. Also maps to MS-DRG 018.
6A550Z2 / 6A551Z2Apheresis, leukapheresis, single/multipleStage 1 apheresis encounter (when billed inpatient).
Document the indication-specific eligibility gate explicitly in the PA. ICD-10 alone is not sufficient. For 2L LBCL (TRANSFORM): document "primary refractory" OR "relapse within 12 months of first-line chemoimmunotherapy." For 3L+ LBCL (TRANSCEND NHL 001): ≥2 prior lines including anthracycline + anti-CD20 mAb. For CLL/SLL (TRANSCEND CLL 004): ≥2 prior lines including BTK inhibitor failure AND BCL-2 inhibitor failure — both must be explicitly documented; this is the most common CLL/SLL PA denial driver because the dual-failure gate is new to many payer policies. For FL: ≥2 prior lines including anti-CD20 + alkylator. For MCL: prior BTKi failure.

Site of care, place of service & DRG/APC mapping FY 2026 IPPS/OPPS verified May 2026

Breyanzi has the highest outpatient infusion share in the CD19 CAR-T class because of its low Grade 3+ CRS profile. Many payers default outpatient for low-risk Breyanzi cases.

StageSettingPOSClaim formPayment mechanism
Stage 1 ApheresisOutpatient hospital / FACT apheresis suite22UB-04 / 837IOPPS APC (apheresis-related)
Stage 1 Apheresis (office)Cellular therapy office at FACT center11CMS-1500 / 837PMPFS line-item 38206/0540T
Stage 3 LymphodepletionHospital outpatient infusion22UB-04 / 837IOPPS APC + J9185 + J9070
Stage 3 Lymphodepletion (alt)Oncology office11CMS-1500 / 837PJ9185 + J9070 line-item
Stage 4 CAR-T (inpatient)Inpatient FACT-accredited center21UB-04 / 837IMS-DRG 018 (CAR-T Immunotherapy) bundled
Stage 4 CAR-T (outpatient - common)Hospital outpatient cellular therapy22UB-04 / 837IOPPS APC 9248 (or current CAR-T APC) + Q2054 + 0537T-0541T
Stage 5 CRS readmitInpatient21UB-04 / 837IDRG by principal manifestation (sepsis, ARDS, encephalopathy)

MS-DRG 018 details

Effective FY 2021, CMS introduced MS-DRG 018 - "Chimeric Antigen Receptor (CAR) T-cell Immunotherapy" as a dedicated CAR-T DRG. Before FY 2021, CAR-T admissions defaulted to MS-DRG 016 (Autologous Bone Marrow Transplant w/ CC/MCC) which significantly under-reimbursed the cellular product cost. MS-DRG 018 is assigned when the ICD-10-PCS principal procedure is XW033C3, XW043C3, or a related new-technology code for autologous CAR-T administration. The relative weight for MS-DRG 018 is among the highest in the IPPS to reflect the high cell product acquisition cost. For inpatient Breyanzi admissions, the lower observed CRS-driven length of stay can mitigate the DRG-shortfall risk that affects Yescarta and Tecartus B-ALL admissions.

MS-DRG 016 vs 018: MS-DRG 016 is reserved for traditional autologous bone marrow transplant cases; MS-DRG 018 is the dedicated CAR-T DRG. Submitting an XW033C3 procedure code with an MS-DRG 016 grouper output usually indicates an error in the encoder or DRG grouper version - verify against the current FY IPPS Final Rule grouper.

Outpatient CAR-T - APC payment (especially important for Breyanzi)

Breyanzi has the highest outpatient infusion share in CD19 CAR-T because of its low CRS Grade 3+ rate. CMS established a CAR-T outpatient APC pathway; the specific APC number is updated annually in the OPPS Final Rule (APC 9248 has been used historically; verify the current rule). Outpatient billing reports Q2054 as a separately payable line item plus the 0537T-0541T administration set. If CRS develops within 7-30 days, admit to inpatient under a CRS-driven DRG (not back into MS-DRG 018).

Site-of-service trends, May 2026: approximately 15-25% of CD19 CAR-T cases overall now run through outpatient pathways at high-volume cellular therapy centers. For Breyanzi specifically, outpatient share is materially higher (estimated 30-50% at qualifying centers for low-burden LBCL and CLL/SLL cases) because of the low Grade 3+ CRS rate. Many commercial payers explicitly steer Breyanzi to outpatient pathway when the patient is otherwise eligible. CLL/SLL outpatient pathway is still policy-emerging post-March 2024 approval. Verify per-payer.

Claim form field mapping - 4 claims, one encounter BMS + CMS verified May 2026

The CAR-T encounter spans 4 separate claims. Each has its own form, fields, and PA reference.

Claim A — Apheresis (Stage 1)

InformationUB-04 / 1500 fieldNotes
HCPCS / CPT24D (1500) or 44 (UB-04)38206 or 0540T per payer policy
ICD-10-CM21 (1500) or 67 (UB-04)Underlying diagnosis (e.g., C83.30 DLBCL, C91.10 CLL, C82.0x FL, C83.10 MCL)
ICD-10-PCS (inpatient only)74 (UB-04)6A550Z2 for the leukapheresis procedure
PA reference23 (1500) or 63 (UB-04)CAR-T PA approval number from payer

Claim B — Lymphodepletion (Stage 3)

InformationFieldNotes
Fludarabine24DJ9185 units = mg administered (1 mg = 1 unit); JZ or JW per waste; 30 mg/m^2 x 3 days
Cyclophosphamide24DJ9070 per 100 mg unit basis; 300 mg/m^2 x 3 days (lower than Yescarta's 500 mg/m^2)
Admin CPT24D96413 + 96415 per chemo infusion day
NDC24A shadedN4 + 11-digit NDC for each chemo agent
ICD-1021Underlying diagnosis + Z51.11 (encounter for chemotherapy)

Claim C — CAR-T infusion (Stage 4)

InformationFieldNotes
Drug HCPCS44 (UB-04)Q2054 - 1 unit per single dose (covers both CD8 + CD4 bags)
NDC43 (UB-04)Patient-specific lot from chain-of-identity label (BMS/Juno labeler 73154, product suffix 001). Both bags share the same NDC family with bag-specific COI identifiers.
ICD-10-CM principal67 (UB-04)Primary indication (e.g., C83.30 DLBCL, C91.10 CLL, C82.0x FL, C83.10 MCL)
ICD-10-PCS principal74 (UB-04)XW033C3 (peripheral) or XW043C3 (central) - drives MS-DRG 018 (inpatient only)
CAR-T admin CPTs44 (UB-04)0537T, 0538T, 0539T, 0540T, 0541T per service rendered (outpatient pathway). The two-bag sequential infusion is ONE 0540T administration.
REMS confirmationChart attachment + PABREYANZI REMS certification letter for facility and prescriber (NOT Yescarta or Tecartus REMS — BMS programs are separate)
FACT documentationPA attachmentFACT or FACT-JACIE accreditation certificate
2L LBCL timing (TRANSFORM)PA narrative + chartFor 2L LBCL: explicit "primary refractory" or "relapse within 12 months" documentation
BTKi + BCL-2i failure (CLL/SLL)PA narrative + chartFor CLL/SLL: document BOTH prior BTKi (ibrutinib/acalabrutinib/zanubrutinib) AND prior BCL-2i (venetoclax) exposures with dates and reason for stopping each
BTKi failure (MCL)PA narrative + chartFor MCL: document prior BTK inhibitor exposure, dates, reason for stopping

Claim D — CRS / ICANS readmission (Stage 5, if applicable)

InformationFieldNotes
Principal ICD-10-CM67 (UB-04)Principal manifestation (sepsis A41.x, ARDS J80, encephalopathy G93.x) - NOT D89.83x as principal
Secondary ICD-10-CM67 (UB-04)D89.831-D89.835 (CRS by grade), G92.0x (ICANS), T80.89XA (other complication post-infusion) as secondary
Tocilizumab44 (UB-04)J3262 bundled in DRG when administered inpatient
Z-code67 (UB-04)Z51.11 history of CAR-T receipt may be added per coding guidance
Phase 3 Get paid REMS + FACT + indication-specific eligibility gate. Five indications, five PA narratives. CLL/SLL requires the dual BTKi + BCL-2i documentation that is newest to payer policy.

Payer policy snapshot Reviewed May 2026

All major payers require PA, FACT documentation, REMS enrollment confirmation, and indication-specific eligibility documentation. CLL/SLL is the most policy-immature space.

PayerPA?Key requirementsSite-of-care UM
UnitedHealthcare
Oncology Cellular Therapy Policy
Yes FACT certification, BREYANZI REMS center (separate from Kite REMS), prior lines per indication, ECOG 0-2 (varies), no active CNS-3 disease, no active autoimmune disease, adequate organ function. For 2L LBCL: explicit "primary refractory" or "relapse within 12 months" timing. For CLL/SLL: documented prior BTKi failure AND prior BCL-2i failure. Approved CAR-T center only; outpatient pathway commonly approved for Breyanzi at qualifying centers given low Grade 3+ CRS profile.
Aetna
CPB CAR-T cellular therapy
Yes FACT + BREYANZI REMS, indication-specific prior lines, ECOG 0-2. CLL/SLL policy updated post-March 2024 approval — verify policy revision date before submission Yes; outpatient pathway widely available for Breyanzi LBCL/CLL low-risk cases
Cigna
CAR-T Coverage Policy
Yes Aligned with FDA label and NCCN B-cell lymphoma / NCCN CLL/SLL / NCCN ALL Guidelines; FACT + REMS; NCCN CLL/SLL Guidelines list Breyanzi as Category 2A in the post-BTKi + post-BCL-2i setting Plan-specific; many have cellular-therapy site steering favoring outpatient Breyanzi at qualifying centers
Medicare (NCD 110.24)
National Coverage Determination
No formal PA NCD 110.24 covers FDA-approved autologous CAR-T for FDA-approved indications at a FACT-accredited (or equivalent) hospital with appropriate ICD-10. All five Breyanzi indications (LBCL 3L+, LBCL 2L, CLL/SLL, FL, MCL) are covered under the same NCD. Coverage with Evidence Development sunset 2022. N/A FFS (Medicare Advantage plans apply their own UM, often allowing outpatient Breyanzi)

NCCN Guidelines

NCCN B-Cell Lymphomas Guidelines (current version) include Breyanzi as a recommended option for R/R LBCL at both 2L (TRANSFORM) and 3L+ (TRANSCEND NHL 001), for FL after ≥2 prior lines (TRANSCEND FL), and for MCL after BTKi failure. NCCN CLL/SLL Guidelines list Breyanzi as Category 2A in the post-BTKi + post-BCL-2i setting following the March 2024 FDA approval. NCCN compendium support strengthens coverage arguments and is particularly important for CLL/SLL given the relative newness of the FDA approval.

Required PA documentation checklist

  • FACT (or FACT-JACIE) accreditation certificate for the treatment center
  • BREYANZI REMS certification letter for the prescribing physician and the facility (NOT the YESCARTA or TECARTUS REMS letter — manufacturer-specific certifications are independent)
  • Prior therapy log: each regimen, dates, response, reason for discontinuation
  • Indication-specific gate documentation:
    • 2L LBCL: "primary refractory" OR "relapse within 12 months of first-line"
    • 3L+ LBCL: ≥2 prior lines including anthracycline + anti-CD20 mAb
    • CLL/SLL: prior BTKi exposure (ibrutinib/acalabrutinib/zanubrutinib) failure AND prior BCL-2i (venetoclax) failure — both with dates and reason for stopping
    • FL: ≥2 prior lines including anti-CD20 + alkylator
    • MCL: prior BTK inhibitor failure
  • ECOG performance status (most policies require 0-2)
  • Diagnostic pathology confirming CD19+ disease (flow cytometry)
  • Imaging / disease burden assessment within recent window (per payer policy, often 30-60 days)
  • CNS disease exclusion documentation
  • Cardiac and pulmonary clearance (LVEF, pulmonary function tests as required)
  • Absence of active autoimmune disease requiring systemic immunosuppression

Medicare reimbursement CMS Q2 2026 (live)

Q2054 has a quarterly ASP payment limit; MS-DRG 018 sets the inpatient DRG payment; OPPS APC handles outpatient (the most common Breyanzi pathway).

Q2 2026 payment snapshot — Q2054

Effective April 1 – June 30, 2026 · Based on Q4 2025 ASP submissions

Q2054 ASP + 6%
$562,260.836
per single therapeutic dose (covers both bags)
MS-DRG 018 base
FY 2026 IPPS
CAR-T Immunotherapy DRG; weight set in IPPS Final Rule
NTAP status
Expired
Original Breyanzi NTAP cycle from FY 2022 ended after FY 2024 - verify each FY
Q2054 ASP has been trending upward. Recent ASP file values for Q2054 have moved from ~$516K (early 2025) to ~$562K (Q2 2026), reflecting BMS price actions and the broadened indication footprint. Quarter-to-quarter variability is modest but the overall trajectory is meaningfully positive. When Q2054 is not ASP-priced in a current quarter, MACs default to invoice pricing (provider's acquisition cost + 6%) or WAC. Verify the current quarter's ASP file before quoting reimbursement.

MS-DRG 018 - CAR-T Immunotherapy

Inpatient CAR-T admissions are reimbursed under MS-DRG 018, introduced in FY 2021. The DRG weight is set annually in the IPPS Final Rule and reflects the high cellular product acquisition cost. For Breyanzi specifically, inpatient share is materially lower than for Yescarta or Tecartus because of the outpatient-friendly CRS profile. When Breyanzi is administered inpatient, MS-DRG 018 still typically falls short of total acquisition + admission cost in many cases, though the gap is somewhat smaller than for CD28-domain CAR-T because of shorter average length of stay.

NTAP history

  • FY 2022 - FY 2024: Breyanzi received CMS NTAP add-on payment after the February 2021 LBCL approval, recognizing the gap between historical DRG payment and acquisition cost.
  • FY 2025 onward: NTAP for lisocabtagene maraleucel expired after the standard 3-year window. Breyanzi inpatient admissions are now reimbursed under MS-DRG 018 alone.
  • Verify each FY: CMS occasionally extends or revises CAR-T add-on policy through the IPPS Final Rule. Confirm in the current Final Rule before assuming or disclaiming NTAP. The CLL/SLL, FL, and MCL approvals of 2024 did not trigger new NTAP windows.

Outpatient OPPS APC (important for Breyanzi)

Outpatient CAR-T infusion is the dominant Breyanzi pathway. Payment runs through OPPS via a CAR-T-specific APC. APC 9248 has historically been used; CMS updates the precise APC and rate annually in the OPPS Final Rule. Q2054 is paid separately under OPPS when the infusion is outpatient (it is not packaged into the APC). Always verify the current OPPS Addendum B for the precise APC assignment. For Breyanzi, the outpatient pathway is the financial planning baseline at most high-volume cellular therapy centers, with inpatient reserved for higher-risk patients or institutional preference.

Coverage

Medicare coverage of CAR-T is governed by NCD 110.24 (Chimeric Antigen Receptor T-cell Therapy). The NCD covers FDA-approved autologous CAR-T for FDA-approved indications administered at a facility enrolled in the FDA-required REMS program and with FACT (or equivalent) accreditation. Coverage with Evidence Development requirements (CED) sunset in 2022; standard coverage applies. All five Breyanzi indications (LBCL 3L+, LBCL 2L, CLL/SLL, FL, MCL) are covered under the same NCD without separate coverage decisions, including the March 2024 CLL/SLL approval.

Patient assistance — BMS Cell Therapy 360 BMS verified May 2026

  • BMS Cell Therapy 360: BMS-administered patient hub for Breyanzi and Abecma — benefits investigation, prior authorization assistance, appeal support, copay support (commercial-only), case-management through the multi-stage CAR-T encounter, and coordination of the longer Breyanzi manufacturing turnaround. Confirm the current phone and portal URL on the most recent Breyanzi Patient Brochure shipped with the cellular product.
  • BMS Patient Assistance Foundation (BMSPAF): free product pathway for eligible uninsured and underinsured patients meeting federal poverty level criteria. Application via the patient's CAR-T case manager. bmspaf.org
  • Independent foundations (Medicare-eligible): for Medicare patients facing affordability gaps on lymphodepletion drugs, monitoring, and travel costs - refer to Patient Access Network Foundation (PAN), HealthWell Foundation, and The Leukemia & Lymphoma Society (LLS) Co-Pay Assistance for LBCL, CLL, FL, and MCL. Verify open lymphoma and CLL funds quarterly.
  • Travel and lodging: Breyanzi is administered only at FACT-certified centers, often requiring travel. BMS Cell Therapy 360 and many treatment centers maintain travel grants for patients living > 50-100 miles from a treatment center. LLS maintains lymphoma and CLL travel grants.
Need to model what a specific patient will actually pay after copay assistance, deductible, coinsurance, and OOP max? Run a CareCost Estimate — Q2054 pre-loaded.
Phase 4 Manage toxicity and fix problems Top denial reasons specific to CAR-T billing + the FAQ block.

Common denials & how to fix them

Denial reasonCommon causeFix
#1 - Non-FACT or non-Breyanzi-REMS-certified centerApheresis or infusion at a center without current FACT (or FACT-JACIE) accreditation, OR a center that is Kite-REMS-certified (Yescarta/Tecartus) but NOT separately BMS-Breyanzi-certifiedRefer patient to a BMS-authorized Breyanzi Treatment Center. Submit FACT certificate + BMS BREYANZI REMS letter (not the Kite REMS letter) as PA attachment. There is no workaround.
#2 - CLL/SLL: dual BTKi + BCL-2i failure not documentedPA narrative for CLL/SLL Breyanzi missing explicit prior BTK inhibitor (ibrutinib/acalabrutinib/zanubrutinib) AND prior BCL-2 inhibitor (venetoclax) failure documentation. This is THE most common CLL/SLL denial driver because the dual gate is newest to payer policy.Add BOTH prior exposures: BTKi agent + dates + reason for stopping, AND BCL-2i (venetoclax) + dates + reason. Cite TRANSCEND CLL 004 and NCCN CLL/SLL Guidelines (Category 2A) in the PA narrative. Resubmit.
#3 - 2L LBCL: timing of relapse not documented (TRANSFORM cases)PA narrative for 2L LBCL Breyanzi missing explicit "primary refractory" or "relapse within 12 months of first-line" languageAdd explicit timing language to PA. Document last first-line dose date, relapse date, and the interval. Cite TRANSFORM and FDA label. Resubmit.
#4 - Prior therapy lines not satisfied (3L+ LBCL, FL)PA narrative missing prior lines documentation per indication (anthracycline + anti-CD20 for LBCL; anti-CD20 + alkylator for FL)Submit complete prior therapy log with regimen, dates, response, reason for stopping.
#5 - MCL: BTKi failure not documentedPA narrative for MCL Breyanzi missing explicit BTKi exposure history (ibrutinib/acalabrutinib/zanubrutinib)Add explicit BTKi documentation: agent, dates, reason for stopping. Resubmit.
#6 - REMS enrollment missing or wrong productBREYANZI REMS certification letter not in chart or PA, OR the wrong product's REMS letter submitted (Kite REMS letter on a Breyanzi claim)Submit BMS-issued BREYANZI REMS certification for prescriber and facility. Kite (Yescarta/Tecartus) REMS does NOT count for Breyanzi.
#7 - Apheresis-to-infusion timeline not documentedChain of custody from apheresis through the longer Breyanzi manufacturing (~24-35 days) to infusion not clearly mapped on the claim fileDocument apheresis date, ship date, manufacturing start, CD8 / CD4 separate processing milestones (if known), return ship date, and infusion date. Attach BMS chain-of-identity records. Use Z-codes and accurate DOS on each stage's claim.
#8 - Wrong Q-code (Q2054 vs Q2041 or Q2042)Submitting Q2041 (Yescarta) or Q2042 (Kymriah) on a Breyanzi claim — common when EHR templates default to the most commonly billed CAR-TVerify Q-code against the chain-of-identity label on the physical cellular product bags. Breyanzi carton NDC starts with 73154-001-XX (BMS labeler); Kite Q2041/Q2053 use 71287; Novartis Q2042 uses its own labeler. Resubmit with correct code.
#9 - CRS / ICANS not coded properlyD89.83x (CRS by grade) or G92.0x (ICANS) not coded as secondary on the CAR-T admission or readmission — less common with Breyanzi given low rates but still required when presentAdd D89.831-D89.835 by clinical grade on the CAR-T admission's secondary diagnosis list. For readmissions, code principal manifestation + CRS/ICANS as secondary.
#10 - Two-bag billing errorBilling Q2054 twice (once for CD8 bag, once for CD4 bag) — the two-bag sequential infusion is ONE therapeutic doseSubmit ONE unit of Q2054 covering both bags. The 0540T administration is also one service, not two. Rebill if doubled.
#11 - Wrong DRG (MS-DRG 016 vs 018)Encoder grouping CAR-T admission to MS-DRG 016 (autologous BMT) instead of 018 (CAR-T)Confirm XW033C3 / XW043C3 principal PCS code is coded and that encoder is current-FY IPPS grouper. Rebill if DRG was assigned 016 in error.
#12 - Lymphodepletion dose mismatchYescarta-style cyclophosphamide 500 mg/m^2 billed when patient received Breyanzi-protocol 300 mg/m^2 (or vice versa)Match J9070 units to the Breyanzi label regimen (300 mg/m^2 x 3 days = ~17 total units for 1.85 m^2 BSA). Document indication and dosing in chart.
#13 - NDC not validatedPatient-specific lot NDC (73154-001-XX) not in payer formulary master file — the BMS labeler 73154 is newer than the longer-established Kite 71287Escalate to medical drug review; reference BMS chain-of-identity. BMS Cell Therapy 360 can supply documentation to payer escalation queues.
#14 - Outpatient pathway rejected (payer-policy mismatch)Outpatient Breyanzi billed at a center where payer policy requires inpatient infusion despite Breyanzi's low CRS profileSubmit risk stratification + Breyanzi safety profile data; cite the < 5% Grade 3+ CRS rate in TRANSCEND NHL 001 and TRANSFORM. If still rejected, admit inpatient and rebill MS-DRG 018. Verify each payer's Breyanzi-specific outpatient policy at the start of PA, not at the claim level.

Frequently asked questions

What is the HCPCS code for Breyanzi?

Breyanzi (lisocabtagene maraleucel) is billed under HCPCS Q2054 — "Lisocabtagene maraleucel, up to 110 million autologous anti-CD19 CAR positive viable T cells, including leukapheresis and dose preparation procedures, per therapeutic dose." The unit basis is one therapeutic dose per single infusion encounter; the descriptor's 110-million cell-count is lower than Yescarta and Tecartus (200 million) because of Breyanzi's defined 1:1 CD8:CD4 composition. The descriptor explicitly bundles leukapheresis and dose preparation. The two component bags (CD8 + CD4) are part of one therapeutic dose — bill ONE unit of Q2054, not two.

How is Breyanzi different from Yescarta?

Both are autologous anti-CD19 CAR-T but with three critical differences. (1) Costimulatory domain: Breyanzi uses 4-1BB; Yescarta uses CD28. 4-1BB drives slower, more controlled expansion with lower peak CRS / ICANS. (2) Composition: Breyanzi is manufactured to a defined 1:1 CD8:CD4 ratio (two separately enriched bags); Yescarta is a single unfractionated bag. (3) Manufacturer / hub: Breyanzi is BMS/Juno with BMS Cell Therapy 360; Yescarta is Kite/Gilead with Kite Konnect. Breyanzi posts the lowest Grade 3+ CRS rate in CD19 CAR-T (< 5%) and is the most outpatient-friendly product. Yescarta has faster manufacturing (~14-17 days vs ~24-35 for Breyanzi). Q2054 vs Q2041 are NOT interchangeable.

What does TRANSCEND CLL 004 mean for Breyanzi billing in CLL/SLL?

TRANSCEND CLL 004 (Lancet 2023, Siddiqi T et al.) established Breyanzi for adult R/R chronic lymphocytic leukemia or small lymphocytic lymphoma after at least 2 prior lines including a BTK inhibitor AND a BCL-2 inhibitor. FDA granted accelerated approval March 14, 2024 - Breyanzi is the first and only CAR-T cell therapy approved in CLL/SLL. For PA, both prior BTKi (ibrutinib/acalabrutinib/zanubrutinib) AND prior BCL-2i (venetoclax) failures must be explicitly documented with dates and reason for stopping each. Some commercial payers were slow to update CAR-T policies after March 2024 — cite NCCN CLL/SLL Guidelines (Category 2A) and the FDA label directly in PA submissions for policy-lagging payers. This is the most common CLL/SLL Breyanzi denial driver.

What does TRANSFORM mean for Breyanzi billing in 2L LBCL?

TRANSFORM (Lancet 2022, Kamdar M et al.) established Breyanzi for primary refractory or early-relapsing (within 12 months) LBCL in the second-line setting vs standard chemoimmunotherapy + auto-HSCT. FDA approved Breyanzi for 2L LBCL June 24, 2022 — the second CAR-T approved at 2L (after Yescarta's April 2022 ZUMA-7). For PA, document explicit "primary refractory" or "relapse within 12 months of first-line." Missing this timing language is the #1 PA denial driver in 2L Breyanzi cases. TRANSFORM's ~1% Grade 3+ CRS rate is the principal argument for outpatient pathway approval at qualifying centers.

What does TRANSCEND NHL 001 mean for Breyanzi billing in 3L+ LBCL?

TRANSCEND NHL 001 (Lancet 2020, Abramson JS et al.) established Breyanzi for 3L+ R/R LBCL including DLBCL NOS, high-grade B-cell lymphoma, PMBCL, and FL grade 3B. FDA approved Breyanzi for 3L+ LBCL February 5, 2021. The PA must document at least 2 prior lines including an anti-CD20 mAb and an anthracycline-based regimen (or document why anthracycline was inappropriate). The TRANSCEND NHL 001 cohort included patients with secondary CNS lymphoma and poor performance status, broadening the practical eligibility envelope vs ZUMA-1.

Why is Breyanzi the most outpatient-friendly CD19 CAR-T?

Two reasons: (1) the 4-1BB costimulatory domain drives slower expansion with lower peak CRS; (2) the defined 1:1 CD8:CD4 composition limits dose variability. Together these produce the lowest Grade 3+ CRS rate in the CD19 class (typically < 5%). More payers approve Breyanzi outpatient pathway than Yescarta or Tecartus; outpatient billing reports Q2054 under OPPS APC (9248 historically) plus the 0537T-0541T administration set. The trade-off is the longer Breyanzi manufacturing turnaround (~24-35 days vs ~14-17 for Yescarta).

What is the multi-stage CAR-T billing workflow for Breyanzi?

Five stages: (1) Apheresis — CPT 38206 or 0540T at a FACT-accredited center; (2) Manufacturing wait of approximately 24-35 days (longest in CD19 class due to separate CD8 / CD4 processing) with no billing; (3) Lymphodepletion with fludarabine 30 mg/m^2 (J9185) and cyclophosphamide 300 mg/m^2 (J9070) days -5 to -3 — note the lower cyclophosphamide dose vs Yescarta; (4) CAR-T infusion — Q2054 single dose (covers both CD8 and CD4 bags) plus the 0537T-0541T administration set; (5) CRS/ICANS monitoring — lowest rates in CD19 class, most outpatient-eligible product. Stages 3-5 may combine into one inpatient admission (MS-DRG 018) or run as a true outpatient pathway across multiple OPPS encounters.

What are MS-DRG 016 and 018 for CAR-T?

Effective FY 2021 CMS created MS-DRG 018 ("Chimeric Antigen Receptor (CAR) T-cell Immunotherapy") as the dedicated CAR-T DRG. MS-DRG 018 is assigned when the ICD-10-PCS principal procedure is XW033C3 / XW043C3 or related CAR-T new-tech codes. MS-DRG 016 covers some autologous bone marrow transplant cases — it is not the right CAR-T DRG. For Breyanzi specifically, a significant fraction of cases bypass inpatient entirely and run through OPPS APC, but for those that do admit inpatient, MS-DRG 018 is the correct grouper output.

Does Breyanzi have NTAP add-on payment status?

Breyanzi received CMS NTAP starting FY 2022 (after the February 2021 LBCL approval); NTAP for lisocabtagene maraleucel expired after FY 2024. Breyanzi inpatient admissions are now reimbursed under MS-DRG 018 alone, without separate NTAP. The 2024 CLL/SLL, FL, and MCL approvals did not trigger new NTAP windows. Verify each FY IPPS Final Rule because CMS occasionally extends or revises CAR-T add-on policy.

What FACT accreditation is required?

Breyanzi may only be administered at facilities certified through the BREYANZI REMS, which requires FACT (or FACT-JACIE) accreditation for cellular therapy plus on-site CRS/ICANS management capability, immediate tocilizumab availability, and ICU backup. BMS maintains the list of certified treatment centers through BMS Cell Therapy 360. A center certified for Yescarta or Tecartus (Kite products) is NOT automatically Breyanzi-certified — manufacturer-specific REMS programs are independent. Confirm BMS Breyanzi certification BEFORE Stage 1.

Outpatient vs inpatient CAR-T - which setting do I bill for Breyanzi?

For Breyanzi specifically, outpatient infusion is materially more common than for other CD19 CAR-T products because of the low Grade 3+ CRS rate. Estimated outpatient share is 30-50% at qualifying high-volume centers for low-burden LBCL and CLL/SLL cases. Outpatient billing reports Q2054 as a separately payable OPPS line (APC 9248 historically) plus the 0537T-0541T administration codes. Inpatient admissions still bill under MS-DRG 018 with the Q2054 line bundled. Verify per-payer; CLL/SLL outpatient pathway is still policy-emerging post-March 2024 approval.

What apheresis CPT do I bill for Breyanzi - 38205, 38206, or 0540T?

38206 (autologous hematopoietic harvesting) has historically been the most common code for CAR-T leukapheresis. 38205 is allogeneic and does not apply to autologous CAR-T. 0540T is a Category III code specific to CAR-T-associated apheresis service. Payer acceptance varies. The Breyanzi apheresis is identical to other CD19 CAR-T from the billing standpoint; the Breyanzi-specific CD8 / CD4 separation happens at the BMS manufacturing facility, not at the apheresis center.

Why is the two-bag infusion billed as one unit of Q2054?

Breyanzi is manufactured as a defined 1:1 CD8:CD4 composition in two separate cryopreserved bags, but the FDA label and the HCPCS descriptor define one therapeutic dose as the sequential administration of both bags (CD8 first, then CD4 minutes later). Bill ONE unit of Q2054 covering the entire administration. The 0540T administration code is also billed once for the sequential service. Submitting two units of Q2054 (one per bag) is a billing error and will be denied or recouped.

How is CRS readmission after Breyanzi billed?

If the patient is infused outpatient (common for Breyanzi) and develops Grade 2+ CRS or ICANS requiring inpatient admission within 30 days, the readmission is billed under the inpatient DRG for the principal manifestation (sepsis, respiratory failure, encephalopathy) with D89.83x (CRS) and G92.0x (ICANS) as secondary diagnoses. Tocilizumab (J3262) is billable inpatient bundled in DRG; outpatient is line-item billable. Operationally, Breyanzi CRS readmission is the least common in the CD19 CAR-T class because of the < 5% Grade 3+ CRS rate.

What happens if Breyanzi manufacturing fails - is re-collection billable?

Breyanzi manufacturing failure rates have historically been comparable to or slightly higher than Yescarta because of the more complex CD8 / CD4 separation and dual-bag formulation. BMS policy historically provides manufacturing-failure replacement at no additional drug cost — verify the current BMS policy through BMS Cell Therapy 360. The repeat apheresis (38206 or 0540T) is generally separately billable; document the manufacturing failure with the BMS case manager and submit a fresh PA referencing the prior approval. The longer Breyanzi vein-to-vein adds operational pressure when a re-collection is required — plan supportive bridging therapy accordingly.

Reference Sources & methodology Every claim on this page is sourced. Methodology and review history below.

Source documents

  1. Breyanzi HCP page (Bristol-Myers Squibb)
    Manufacturer dosing, REMS, treatment center locator, and BMS Cell Therapy 360 patient support reference
  2. DailyMed — BREYANZI (lisocabtagene maraleucel) Prescribing Information
    FDA-approved label, most recent revision (BLA 125714)
  3. FDA Approval Announcement — Lisocabtagene Maraleucel for R/R LBCL (Feb 5, 2021)
    Initial 3L+ LBCL approval (TRANSCEND NHL 001)
  4. FDA Approval — Breyanzi 2L R/R LBCL (Jun 24, 2022, TRANSFORM)
    Second-line LBCL approval
  5. FDA Accelerated Approval — Breyanzi R/R CLL/SLL (Mar 14, 2024, TRANSCEND CLL 004)
    First and only CAR-T approved in CLL/SLL
  6. FDA Accelerated Approval — Breyanzi R/R Follicular Lymphoma (May 15, 2024, TRANSCEND FL)
    FL indication
  7. FDA Approval — Breyanzi R/R Mantle Cell Lymphoma (May 30, 2024)
    MCL indication
  8. FDA Approval — Breyanzi R/R Marginal Zone Lymphoma (December 4, 2025, TRANSCEND FL-MZL cohort)
    First CAR-T approved in MZL — TRANSCEND FL-MZL cohort, NCT04245839; supplemental BLA, accelerated approval
  9. ClinicalTrials.gov — TRANSCEND FL/MZL (NCT04245839)
    Pivotal R/R FL and R/R MZL trial registration
  10. Abramson JS et al. - TRANSCEND NHL 001 (R/R LBCL 3L+), Lancet 2020
    Pivotal LBCL data — basis of February 2021 FDA approval
  11. Kamdar M et al. - TRANSFORM (2L R/R LBCL), Lancet 2022
    Pivotal 2L LBCL data — basis of June 2022 FDA approval
  12. Siddiqi T et al. - TRANSCEND CLL 004 (R/R CLL/SLL), Lancet 2023
    Pivotal CLL/SLL data — basis of March 2024 accelerated approval
  13. FACT (Foundation for the Accreditation of Cellular Therapy)
    Accreditation standards for cellular therapy programs (FACT and FACT-JACIE)
  14. CMS — Medicare Part B Drug ASP Pricing File
    Q2 2026 quarterly file, effective April 1 – June 30, 2026
  15. CMS — FY 2026 IPPS Final Rule (MS-DRG 016 / 018, NTAP)
    CAR-T DRG assignments and add-on payment policy
  16. CMS — CY 2026 OPPS Final Rule (CAR-T outpatient APC)
    Outpatient CAR-T APC assignment and rate — particularly important for Breyanzi
  17. CMS NCD 110.24 — Chimeric Antigen Receptor (CAR) T-cell Therapy
    National Coverage Determination for CAR-T
  18. NCCN B-Cell Lymphomas Guidelines
    LBCL, FL, MCL sections — Breyanzi listed across indications
  19. NCCN CLL/SLL Guidelines
    Breyanzi Category 2A in post-BTKi + post-BCL-2i setting
  20. BMS Patient Assistance Foundation
    Patient assistance program covering Breyanzi for uninsured and underinsured patients
  21. FDA National Drug Code Directory

About this page

We maintain this page as a living reference. Medicare ASP pricing is bound to our underlying CareCost data layer and refreshes automatically when CMS publishes new quarterly files. Coding, MS-DRG/APC, and policy content is reviewed at least quarterly and updated whenever a source document changes.

Found an error? Email hello@carecostestimate.com.

Refresh cadence

ElementCadenceHow it's refreshed
Medicare ASP pricing (Q2054)QuarterlyAuto-bound to CareCost ASP layer; updates on CMS file release.
MS-DRG 018 weight + OPPS APC rateAnnualReviewed against the current FY IPPS Final Rule and CY OPPS Final Rule.
NTAP statusAnnualVerified against the current FY IPPS Final Rule.
Payer policies (UHC, Aetna, Cigna) — CLL/SLL especiallySemi-annualManual review against published payer policy documents; CLL/SLL coverage policy still maturing post-March 2024 approval.
HCPCS / CPT (Category III)AnnualReviewed against CMS HCPCS quarterly files and AMA CPT releases for Category I conversions.
NDC, dosing, FDA label, BREYANZI REMSEvent-drivenTied to manufacturer document version + FDA label revision date + REMS program updates.
FACT accreditation requirementsAnnualVerified against FACT standards revisions.

Reviewer

SME-audited 2026-05-22 — corrections applied. Internal SME review confirmed: HCPCS Q2054 descriptor (up to 110M CAR+ T cells, distinct from Yescarta/Tecartus 200M and from Abecma Q2055/BCMA) matches the FDA label and the CMS Part B ASP file; BLA 125714; defined 1:1 CD8:CD4 composition + 4-1BB costimulatory domain verified; manufacturer source links (breyanzi.com, bmspaf.org) live; TRANSCEND NHL 001 (Abramson Lancet 2020), TRANSFORM (Kamdar Lancet 2022), TRANSCEND CLL 004 (Siddiqi Lancet 2023) citations carry working DOIs in the source list; current DailyMed label revision (Feb 20, 2026) verified. Correction applied: a sixth FDA-approved indication — relapsed/refractory marginal zone lymphoma (MZL), approved December 4, 2025 based on the TRANSCEND FL-MZL cohort (NCT04245839), and the first CAR-T ever approved in MZL — was missing from the initial draft and has been added across the indications row, the class-comparison table, the about section, the pivotal trials list, the FAQ, and the source list. High-stakes operational items (current FY MS-DRG 018 weight, OPPS APC assignment, CLL/SLL and MZL payer policy maturation) remain on quarterly/annual refresh per the cadence table above.

Change log

  • — SME audit pass. Added sixth FDA-approved indication: relapsed/refractory marginal zone lymphoma (MZL), approved December 4, 2025 based on the TRANSCEND FL-MZL cohort (NCT04245839) — the first CAR-T ever approved in MZL. Updated indications row, class-comparison table, about-Breyanzi section, pivotal trials list, and FAQ; added FDA MZL approval announcement and ClinicalTrials.gov NCT04245839 to source list. Reviewer callout flipped from "Pending SME review" to "SME-audited — corrections applied".
  • — Initial publication. ASP data: Q2 2026 (live-bound to CMS file at ~$562,260.836). FY 2026 IPPS Final Rule referenced for MS-DRG 016/018 and NTAP status. Multi-stage CAR-T workflow (apheresis through CRS) documented end-to-end with the Breyanzi-specific defined 1:1 CD8:CD4 two-bag composition, 4-1BB costimulatory domain, 30/300 mg/m^2 lymphodepletion regimen, and ~24-35 day manufacturing turnaround. FACT accreditation and BREYANZI REMS gate emphasized as #1 denial driver — including the separate-certification-from-Kite distinction. CD19 CAR-T class disambiguation (Breyanzi vs Yescarta vs Kymriah vs Tecartus, plus BCMA-class Abecma and Carvykti) included for code-selection accuracy. All five FDA-approved indications covered: TRANSCEND NHL 001 (3L+ LBCL), TRANSFORM (2L LBCL), TRANSCEND CLL 004 (first and only CAR-T in CLL/SLL, March 2024), TRANSCEND FL (FL, May 2024), MCL (May 2024). CLL/SLL dual-BTKi-plus-BCL-2i documentation requirement emphasized as #2 PA denial driver. Outpatient pathway emphasized as Breyanzi's operational signature given lowest Grade 3+ CRS rate in CD19 class.

Methodology

Every claim on this page is sourced inline. Pricing reflects the current CMS Part B Drug ASP Pricing File. DRG and APC content is read directly from the current IPPS and OPPS Final Rules. Payer policies are read directly from each payer's published cellular therapy / oncology coverage documents. Indication and dosing are verified against the current FDA Breyanzi label revision. REMS program details are verified through BMS materials. Pivotal trial evidence is cited from peer-reviewed publications (Lancet for all four pivotal trials). We do not paraphrase from billing-software vendor blogs.

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