AAHomecare Offers IFR Analysis
Despite the short duration and limited reach of relief, association says the IFR sets the stage for broader efforts.
- By David Kopf
- May 17, 2018
A week after CMS issued an interim final rule designed to provide limited relief to rural providers from national bid expansion, the American Association for Homecare has released a deeper analysis that was the pros and cons of the IFR.
The IFR would resume the 50/50 blended rate schedule for rural and some non-bid areas starting from June 1 through Dec. 31 and will affect rural areas and non-contiguous areas (Alaska, Hawaii and U.S. territories) that are non-bid areas. The full text of the IFR can be read here.
The IFR didn’t receive much of a warm reception from the industry given that it provides on a short period of relief, and essentially no help for providers in non-bid areas that aren’t rural. AAHomecare took a closer look to tease out the good and the bad points of the IFR.
The association’s analysis shows the IFR is definitely a mixed bag:
- Rural providers and providers that in non-bid areas in Alaska, Hawaii, and US Territories will benefit from rates that are 50 percent 2018 rural fee schedule and 50 percent 2015 fee schedule running from June 1, 2018 to Dec. 31, 2018.
- There is no guidance as to what CMS should due in 2019 and beyond.
- There is no relief for providers that are in non-bid areas that are in the contiguous United States.
- That adjustment mitigates the impact of the stationary oxygen “double dip” cuts for rural and non-contiguous areas for the seven-month relief period. However, the fix isn’t permanent and only lasts for the seven months.
- Continues to extend the exclusion of CRT accessories from competitive bidding.
Significantly, the IFR’s language acknowledges that both providers and beneficiaries are facing challenges due to bid expansion. The language notes that there has been a 7 percent decrease in the number of DEMPOS suppliers from 2015 to 2016. AAHomecare’s research cited several passages from the IFR in which CSM acknowledges that its monitoring of claims data doesn’t alert the agency to “present and imminent threats to beneficiary access that stakeholders have raised in recent months.”
“If CMS continues to pay the fully adjusted payment rates in rural and non-contiguous areas, it could further jeopardize the infrastructure of suppliers that beneficiaries rely on for access to necessary items and services in remote areas of the country,” the IFR reads. “… We recognize that reduced access to DME may put beneficiaries at risk of poor health outcomes or increase the length of hospital stays.”
Ultimately, AAHomecare’s analysis concludes that the industry’s best bet to is to push for a more permanent legislative fix.
“CMS has been very resistant to acknowledge and address these issues in recent years, so the volume and change in tone in these statements is very encouraging,” AAHomecare noted in its statement. “While we will continue to engage CMS and the Administration on long-term, sustainable Medicare reimbursement policy for all suppliers, including those in bidding areas, rural suppliers, and other non-bid suppliers, it’s clear the only realistic near-term avenue for more substantial relief for both rural and other non-bid area suppliers runs through Capitol Hill.”
Bearing that in mind, roughly 150 industry advocates are expected to head to AAHomecare’s Washington Legislative Conference, slated for May 23 and 24 at the Sheraton Pentagon City in Arlington, Va.
“Congressional outreach to CMS and OMB were critical factors in getting the Administration to finish work on the IFR, and these two months will be critical to efforts to keep the House and Senate engaged on both rural and non-bid reimbursement issues, as well as on reforms for the next round of the bidding program,” the association’s statement read.
David Kopf is the Editor of HME Business.