AAHomecare Releases Public Comments on ESRD Rule

Association catalogs a number of ways CMS can improve DMEPOS policies; urges more providers, stakeholders to submit comments.

The American Association for Homecare has submitted its public comments on CMS’s End Stage Renal Disease and DEMPOS proposed rule.

In its comments, AAHomecare supports CMS’s proposal to calculate single payment amounts (SPAs) using lead item pricing, which is similar to the clearing price approach that the industry has desired. It suggests CMS work with the industry to refine the product categories used in lead item pricing;

“Adopting a clearing price methodology, coupled with implementing Congressionally mandated provisions to reduce the influence of non-serious or unqualified bidders, should result in reimbursement rates that better reflect the economic realities of our industry,” noted AAHomecare President and CEO Tom Ryan. “In addition, extending relief for rural suppliers will have a stabilizing effect on that segment, helping ensure that patients in small communities can maintain access to HME.”

AAHomecare’s comments also urge CMS to increase the payment levels in former competitive bidding areas so that they are on par with the SPAs in those areas, and then updated using the consumer price index. It also asked for CPI adjustments for non-mail-order diabetic supplies.

The association praises the proposed rule’s provisions to extend the 50-50 blended rate in rural and non-contiguous, non-bid areas (Hawaii, Alaska and U.S. territories) during from Jan 1, 2019 to Dec. 31, 2020, but calls on applying the rule to all non-bid areas.

In regard to the rule’s proposals for oxygen, AAHomecare’s comments ask CMS to alleviate the impact of applying budget neutrality provisions to stationary oxygen rates in non-CBA areas. It also calls for a more comprehensive approach toward modernizing oxygen policy and creating new payment classes for liquid oxygen and higher reimbursement rates for these products.

Other bidding reforms include:

  • A recommendation that CMS work with stakeholders to replace the gap filling methodology it uses to calculate the payment rate for new and updated HCPCS codes.
  • Divide the standard mobility product category into separate manual and power categories, and move walkers to a different category with hospital beds and other products.
  • Exclude mobility repair items and services from competitive bidding and return the allowables for these parts to the 2015 fee schedule,
  • Exclude nebulizers from bidding.
  • Include bids from small providers in calculating SPAs.
  • Clarify the capacity determination methodology;
  • Increase bidding program transparency, including having auction experts monitor the bidding program.
  • Remove CMS’ authority to bundle payment for CPAP and power mobility products.

“I hope our comments will help spur HME companies and other stakeholders to share their input on the Proposed Rule with CMS, as well,” Ryan added. “The final version of the ESRD/DMEPOS Rule will have a tremendous impact on our industry for years to come, so it’s critical that we make our best case for improving CMS’ reimbursement policy now.”

Providers have until end of day Sept. 10 to submit their public comments on the proposed rule. They can file their comments at bit.ly/2MMEEXb.

About the Author

David Kopf is the Editor of HME Business.

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