WASHINGTON, DC – CMS officially published the DMEPOS proposed rule (CMS-1738-P) originally announced last week in today’s edition of the Federal Register. Comments to this proposed rule are due January 4, 2021. Below are the key takeaways from the proposed rule:
- CMS proposes to make some changes to the fee schedule methodology starting April 1, 2021 or immediately after the PHE, whichever is later. Below are the proposals:
- Rural Areas, Non-CBAs: Make the current methodology of 50/50 blended rates permanent
- Non-contiguous, Non-CBAs: Make the current methodology of 50/50 blended rates permanent
- Non-Rural, Non-CBAs: Maintain 100% adjusted rates (currently, during the PHE, these areas are receiving 75/25 blended rates)
- CBAs (for items not in Round 2021): CMS is seriously considering continuing with the current rates that are in place today and is requesting feedback
- CMS codifies the HCPCS Levels II code application process that is already in place into regulation with some modifications.
- CMS proposes to interpret the “appropriate for use in the home” requirement to expand coverage for external infusion pumps under the DME benefit. If finalized, more drugs and biologicals are expected to be covered under the DME benefit.
- CMS proposes to classify all CGM systems that use a receiver as routinely purchased DME.
- CMS incorporates the changes set in the Further Consolidated Appropriations Act, 2020 (Pub. L. 116-94) that was signed into law on December 20, 2019 into regulation.
You can find AAHomecare’s summary of the proposed rule here. AAHomecare has started working on responding to the proposed rule and will provide comment guidance to our membership. CMS is accepting comment submissions at regulations.gov.
AAHomecare Enlists Dept. of Defense to Support TRICARE Claims Reprocessing
WASHINGTON, DC – AAHomecare has asked the assistant secretary of defense for Health Affairs to direct TRICARE West contractor Health Net Federal Services (HNFS) to automatically reprocess claims to reflect rates granted by CARES Act provisions retroactive to March 6, 2020.
The letter detailed CMS reimbursement changes stemming from the CARES Act and reiterated TRICARE policy establishing that providers must accept the “maximum allowable charge” for DMEPOS based on the Medicare fee schedule.
In our previous experience working with TRICARE, we’ve found that Federal authorities have responded more rapidly when claims issues were raised by suppliers. Accordingly, we are asking suppliers serving TRICARE beneficiaries to ask the Defense Health Agency to direct HNFS to retroactively process claims at the correct rates automatically.
Please use this letter (MS Word doc) as a template for your request, and feel free to add details about your company’s commitment to provide high quality care to TRICARE beneficiaries. Sending your request via regular postal mail is preferred. Contact David Chandler at firstname.lastname@example.org for more information.
Enteral and Parenteral LCDs Slated to Retire on November 12
WASHINGTON, DC – On October 8, the DME MACs announced in a joint statement that the LCDs and Policy Articles for Parenteral Nutrition and Enteral Nutrition will be retiring effective November 12, 2020. Moving forward, for coverage requirements, suppliers will need to reference the National Coverage Determination (NCD) 180.2 – Enteral and Parenteral Nutritional Therapy.
Noridian, the DME MAC contractor for Jurisdictions A & D, is hosting a webinar on November 17th at 1PM (ET) regarding this change. You can register for the webinar titled, “Nutrition Q & A for Correct Coding and Billing after November 12” at the link provided.
AAHomecare has created a comparison of the coverage criteria in the NCD and LCDs. You can find the comparison sheet here. Please note this is not a comprehensive coverage guideline, and suppliers should visit the DME MAC websites for the full coverage requirements.