AAHomecare recently submitted comments on the CMS’ proposed rule on Medicaid and Children’s Health Insurance Plan (CHIP) Managed Care (CMS-2408-P).  AAHomecare’s comments cover a range of issues related to reimbursement, MLR standards, network standards, MCO quality ratings and strategy, and grievances/appeals. Suggestions to the Agency include:

• Option to Develop & Certify a Rate Range: We suggest that CMS require states to conduct studies designed to address whether rates are sufficient to facilitate access to all products and services for patients in all geographical areas of the state. We further suggest that CMS publish guidelines for states to follow when conducting such studies.
• Medicaid Managed Care Quality Rating System: We agree with the establishment of set CMS standards; these are a positive change. We suggest that the standards include all of the fail-safe standards pertaining to rate changes, program changes, and notification time frames. We further suggest that the standards emphasize the quality standards of time frame for payments, authorization time frames, audit programs, and the quality of the provider network.
• Other Comments: Promoting flexibility to the states is appropriate, but there need to be checks and balances in place to ensure proper administration by the Plans. It is important that CMS establish these checks and balances because, at present, states are just handing over control to Plans without providing adequate oversight. Federal funding is a large profit component to Plans, and, therefore, the Plans need to be closely monitored by CMS. There must also be established penalties for those Plans that do not follow the CMS standards.
• See AAHomecare’s comments here.

Kansas Providers Push Back Against Proposal for Severe Medicaid Cuts

TOPEKA, KS – The Kansas Dept. of Health and Environment has proposed cutting rates for most HME items to just 65% of the Medicare non-rural fee schedule, effective retroactively to Jan. 1, 2019.

HME stakeholders in Kansas, led by the Midwest Association for Medical Equipment Services & Supplies (MAMES), have pushed back with comments that point out how these cuts will further impact providers who are already dealing with a challenging Medicare reimbursement environment.  MAMES’ comments highlight how the competitive bidding program has shrunk the ranks of HME suppliers in Kansas and detail the evidence that deep reimbursement cuts are impacting HME patient access, citing industry studies as well as findings from CMS and the Government Accountability Office.

“Further reductions to DME reimbursement for the Medicaid population at 65% of the Non-Rural Medicare fee schedule will devastate all suppliers who care for the Medicaid population,” asserts MAMES in comments shared with Kansas regulators, CMS officials, state legislators, as well as selected members of the Kansas congressional delegation.  “In addition, it will eliminate any estimated Medicaid program savings by shifting those savings to long-term care expenses.”

MAMES later adds that “absolutely no supplier would be able to sustain that type of reimbursement reduction over any period of time,” and warns “Once the suppliers are gone, especially in the rural areas, there are no new suppliers coming in.”

“These proposed rates would be the lowest rates for a Medicaid program in the country,” notes AAHomecare’s vice president of payer relations, Laura Willard, who is working closely with MAMES’ executive director Rose Schafhauser (pictured) on the issue and also submitted comments [link forthcoming] on behalf of AAHomecare.  “Kansas Medicaid is 94% MCO-covered, so the actual amount at risk for the state is small, but the potential impact on HME providers and patients is huge.  The HME community needs to continue to push back against the growing trend of MCOs further discounting Medicaid rates, or providers will be faced with very tough choices on serving this population.”

Proof of Delivery Requirements for Medicare FFS Eligible

WASHINGTON, DC – On January 17, CMS published MLN Matters Article SE19003 regarding the requirements for proof of delivery when a patient becomes Medicare FFS eligible.  For newly eligible beneficiaries that already have a DME item in their home at the time they become eligible for FFS Medicare, suppliers must make sure the item is in proper working order before billing Medicare. Suppliers are required to get either an attestation statement or a new delivery ticket signed indicating the item is in good working order and meets Medicare criteria. This is not a change from previous directives.

You can find SE19003 here.