WASHINGTON, DC – AAHomecare has submitted comments for CMS’ request for feedback on including ventilators and braces to the DMEPOS competitive bidding program.
AAHomecare’s comments focused on CMS’ interest to include ventilators (E0465, E0466, E0467). AAHomecare strongly opposed including ventilators to the program due to the complexity of providing ventilator services to patients and due to the intensive and continual care these patients need. Ventilators are life support systems that replace or support normal ventilatory lung function, it is a DME item that is unlike any other competitively bid item.
AAHomecare also points out that Medicare currently classifies ventilators in a category of items that require “frequent and substantial servicing,” recognizing the intensive and continual service these items require “in order to avoid risk to the patient’s health,” and notes that Medicare has not included any other “frequent and substantial servicing” items in the bidding program to date.
The prospect of adding ventilators to the bidding program has also raised concerns with clinicians and caregivers who support the vulnerable patient cohort who rely on these products. Comments by Nationwide Children’s Hospital in Columbus, Ohio provided examples of how ventilators dramatically improve the lives of young patients with significant respiratory challenges and provided a stark warning on the potential impacts of adding these products to the bidding program:
Adding ventilators to the competitive bidding process for Medicare would be a failure at the start and would adversely affect every pediatric patient in Ohio who uses some form of ventilation for support. Changing the rates of payment for services would essentially put many if not all of these dedicated companies out of business. This would lead to detrimental consequences for the patients they serve.
Due to the changes being made to the structure of competitive bidding in the next round, which is slated to begin in 2021, AAHomecare does not believe it is an appropriate time for CMS to add ventilators, braces, or any other new product categories to the mix. You can find AAHomecare’s comments here.
Medicaid Provisions and Budget Impasse Stall Manual CRT Accessories Legislation
WASHINGTON, DC – H.R. 7217 remains on hold in the Senate. Our sources on Capitol Hill tell us that the issue is not related to the CRT provisions in the bill; the delay is instead due to concerns about the Medicaid language. Coupled with the impasse over Federal spending legislation that has shut down some government functions, the prospects for moving this legislation are narrowing. However, the overwhelming passage in the House (by a 400-11 margin) and strong support from much of the Senate may pave the way for similar action in the next Congressional session.
AAHomecare Weighs in on CDE Templates
WASHINGTON, DC – On December 17, AAHomecare submitted comments to CMS request for information (RFI) on the use of Clinical Data Elements (CDE) templates. The RFI concerns the completion of CDE templates by physicians and non-physician practitioners to order and to document the face-to-face and other appropriate laboratory test results in a manner to qualify a Medicare beneficiary for certain DMEPOS. AAHomecare took this opportunity to support the utilization of the CDE templates to the extent that they replace all other documentation requirements that are currently required. Without the removal of other clinical record requirements, there is no benefit to adding CDE templates.
You can find AAHomecare’s comments here.