ALEXANDRIA, Va. — The American Association for Homecare (AAHomecare) reacted with disappointment that home care provider, patient and pulmonary physician groups were not consulted about a proposed rule affecting Medicare oxygen policy issued on July 27 by the Centers for Medicare and Medicaid Services (CMS).
“Policy for medical oxygen under Medicare deserves review to ensure that the payment system is appropriately aligned with the actual clinical and lifestyle needs of the oxygen patient,” Tom Ryan, chairman of AAHomecare and CEO of Homecare Concepts in Farmingdale, N.Y., said in a news release. “But the changes proposed in this rule do nothing to address the needs of the approximately one million Medicare beneficiaries receiving oxygen therapy at home.
“The American Association for Homecare is concerned that CMS would issue proposals for sweeping changes in oxygen policy without consultation with home oxygen providers or with the pulmonary physician and oxygen-patient communities. Moreover, there is no support in the rule to back the data supporting estimates of cost reductions.”
The rule would establish new classifications and monthly payment amounts for all home oxygen therapy technologies. This includes the creation of a new class for oxygen-generating portable equipment such as portable concentrators and transfilling systems along with separate classes and payment amounts for gaseous and liquid oxygen contents that must be delivered for stationary and portable oxygen equipment following the transfer of ownership to the beneficiary after 36 months For instance, the proposed rule reduces the monthly payment for stationary oxygen systems from an average of $199 to $177. The rule would set the portable add-on fee at $32 per month; an oxygen-generating portable equipment add-on fee at $64; delivery for stationary contents at $101; and delivery of portable contents at $55.
In addition to the new classes and payment amounts, this complex and comprehensive rule proposes myriad other changes that will create new policy and protocols. These will likely create additional costs and administrative burdens to the providers while again shifting more responsibility onto patients for the management of home oxygen therapy technologies.
Oxygen therapy is critical to about one million patients who suffer from respiratory illnesses such as chronic obstructive pulmonary disease (COPD) and who require oxygen therapy under Medicare. Nationwide, as many as 15 million Americans have been diagnosed with COPD.
Ryan noted that, “The logic behind this new rule is still driven by the idea that the chief cost component of oxygen therapy in the home is equipment. The reality is oxygen therapy requires many services that CMS does not account for in its reimbursement.” Last month, AAHomecare issued a report that shows that nearly three-quarters (72 percent) of the cost of providing home oxygen therapy to Medicare patients in their homes represent services, delivery and other operational expenses that benefit patients. Only about one-quarter (28 percent) of the cost represents oxygen equipment. This data was gathered in 2006 by Morrison Informatics in a comprehensive survey of current oxygen therapy.
The American Association for Homecare has endorsed the Home Oxygen Patient Protection Act, H.R. 5513, which was introduced in May by two physicians in Congress — Rep. Joe Schwarz (R-Mich.) and Rep. Tom Price (R-Ga.).