The bid gap and other policy developments effective for 2019 have raised a number of questions regarding reimbursement rates, and VGM Government Relations has released several guidelines to help answer them.
The various points of confusion stem largely from CMS’s final ESRD/DMEPOS rule, which contains provisions such as the bidding gap; additional rural relief; and a new method for calculating single payment amounts (SPAs).
VGM broke down the broader changes for 2019 as follows:
- Rates for the former competitive bidding areas (CBAs) are at the SPA plus 2.5 percent, except for oxygen.
- Oxygen reimbursement in former CBAs is at the SPA adjusted for budget neutrality. VGM has created a PDF that details these amounts by location.
- Diabetic supplies that are not mail-order remain at their current reimbursement rates.
- Items that are not part of the competitive bidding program are to reimbursed at their 2018 rates plus 2.3 percent.
- Rural areas, as well as areas that are both not part of a CBA and not part of the contiguous United States (Alaska, Hawaii and U.S. territories) are reimbursed at 50 percent of the unadjusted fee schedule and 50 percent new adjusted fee schedule.
- Non-rural areas that are not part of competitive bidding areas, but are part of the contiguous United States stay at their current regional rate.
For more granular information, VGM Government Relations provided various resources to help providers looks up specific reimbursements.
To begin with, it set up a DMEPOS Geographic Classifications page, which provides links to customized, state-by-state Google maps that let providers enter an address to determine which type of reimbursement are they are in: a CBA; a rural area; a non-rural, non-bid area; a non-rural, non-contiguous, non-bid area.
VGM also collected some guidance on how providers can use the information on the Competitive Bidding Implementation Contractor (CBIC) web pages to determine rates. Once providers find either the Round One SPAs or Round Two SPAs, they should “scroll to the bottom of the page,” VGM advises. “Choose the appropriate region. This will take you to a compressed folder of Excel spreadsheets and PDFs based on product category. Once you open the chosen spreadsheet, you will need to scroll down to find the competitive area with every bid code and reimbursement rate. These are the 2018 reimbursement rates. You will need to add 2.5 percent increase to these rates. (CMS granted a 2.5 percent CPI increase in 2019 for bid items).”
For rural and non-rural, non-bid area reimbursements, VGM directs providers to go to the January 2019 DMEPOS Fee Schedules page, and download the file named “DME19-A (updated 01/03/19)” which downloads a ZIP file containing Excel spreadsheets and PDFs.
“Choose the excel spreadsheet labeled DMEPOS.JAN or DMEPEN.JAN for enteral supplies,” VGM recommends. “Once opened, you will see the HCPCS codes on the left and the states (R) for rural and (NR) for non-rural rates.”