WASHINGTON, DC – While the bidding window for HME has opened with non-invasive ventilators (NIV) included as part of the program, AAHomecare and respiratory stakeholders continue to advocate for taking these products out of the mix for Round 2021.
AAHomecare will be meeting with CMS officials next week to discuss the issue and is also taking part in meetings with legislators and staff on potential legislation to keep non-invasive ventilators out of the bidding program. The strong support generated on House and Senate sign on letters in June should help generate momentum and build support if these bills take shape in the coming months.
AAHomecare has also shared the new white paper on non-invasive ventilators detailed below with officials at HHS and CMS, as well as with our champions on Capitol Hill.
White Paper Articulates Cost & Value of Home NIV
A work group of the HME/RT Council developed a compelling white paper outlining both the value of non-invasive ventilators (NIV) and what it costs for suppliers to provide NIV, supplies, and comprehensive services to medically complex individuals in the home. The paper, available here, also includes testimonials of two end users who require NIV to manage their medical needs.
“As a group of dedicated professionals working everyday with patients who require non-invasive ventilation and clinical services to live at home with a good quality of life, we want to express the concerns of patients, caregivers, and clinicians on this matter,” explains Roxanne Venard, RRT, with Ascent Respiratory Care, who co-chaired the work group who put together the paper.
“The white paper addresses the service-intensive nature of providing critical life support in the home, including the challenges Durable Medical Equipment companies face in supplying these patients with equipment and clinical services,” adds Venerd. “Most importantly, the white paper includes our patients’ perspective on the importance of access to NIV, and how the competitive bid has potential to limit that access and in turn diminish their quality of life and overall health.”
The white paper is being used in discussions with the Administration and The Hill as an educational tool. It highlights potential equipment, supplies, and personnel costs a supplier incurs when providing NIV, which can cost suppliers thousands of dollars that are not billable separately under Medicare and many other payors. As a service-intensive, life sustaining medical device, the paper emphasizes the role of RTs and qualified personnel in providing careful assessment, ongoing monitoring, extensive education, training, support, titration, and servicing.
“The time, equipment supplies, clinical services, maintenance and 24/7 support required to properly care for an NIV patient comes with a cost,” the paper explains. “Medicare and other payors have a responsibility to their beneficiaries to ensure that NIV policies and reimbursement protect end users’ ability to receive the care, supplies, and equipment needed to manage their health care needs.” It concludes that ventilators are inappropriate for the Competitive Bidding program, which poses significant risk to an already vulnerable NIV patient population.
“Two in five Members of Congress signed Congressional letters to the Administration, joining us and other stakeholders from the clinical and consumer communities in advocating for the removal of NIV from competitive bidding,” explains Tom Ryan, president and CEO of AAHomecare. “This white paper will help us as we continue to seek a regulatory or legislative solution to keep ventilators out of Round 2021 and future bidding rounds.”
See more in the new white paper: Costs and Value of Non-Invasive Ventilation in the Home.
Round 2021: The Covered Document Review is Aug 19 – Will You be Ready?
by Cara Bachenheimer, head of the Government Affairs Practice for Brown & Fortunato
For Round 2021 of competitive bidding, Medicare has issued more information than ever before to help bidders understand how Medicare will assess their financial documentation. To understand what financial documentation is required and how Medicare will use that information, make sure you digest the following:
- The Competitive Bidding Implementation Contractor’s (CBIC’s) “Financial Scoring Methodology Fact Sheet” – This Fact Sheet, released last week, provides brand new information describing how Medicare will evaluate bidders’ financial information and how the CBIC will compute bidders’ financial scores. The Fact Sheet provides tables that detail bidders potential scores, with a maximum score of 100 points: 80 points from the ratios and 20 points from the numerical credit score or rating.
- The CBIC’s “Process for Reviewing Covered Documents Fact Sheet” explains what financial documentation is considered “covered” and how to make sure you can take advantage of this process where the CBIC reviews your documentation for completeness (not accuracy), and will provide you notice within 90 days after August 19 of any missing documentation.
- The “Request for Bids” instructions: see pp. 21-27 and Appendix D on pp. 41-53, where the CBIC explains in detail what kinds of financial documentation must be submitted, including the different requirements depending on your organization’s legal structure.
- The “Required Financial Documents Fact Sheet” reviews the tax return extract, financial statements, and credit report requirements.
Making the Case for HME During the August Recess
WASHINGTON, DC – The House of Representatives plans to wrap up business this Friday, July 26, with the Senate staying on another week, through Aug. 2. Both chambers conclude what is traditionally known as the “August recess” by returning on Monday, September 9.
Seasoned HME advocates know that this period provides a great opportunity to schedule meetings with legislators, attend town halls or similar events, and make a case for HME policy priorities including rural reimbursement relief, fixing the oxygen “double dip,” protecting access to CRT, and keeping ventilators out of the bidding program. More details and resources on these issues can be found on this page with recess resources.
See our Congressional Directory to find basic contact information for your legislators, or email Gordon Barnes at firstname.lastname@example.org for contact info for House and Senate schedulers and healthcare legislative staffers. If you’re a member of a state or regional HME association, you should contact them to see if there are any meetings set that you could join.
Finally, please make sure to thank your legislators on social media (with a picture from the meeting, if possible). Please let Tilly Gambill at email@example.com know about any posts you’ve put up on Twitter or Facebook or if you would like AAHomecare to share your meeting pictures in our social channels.
Provider Compliance Focus Group Meeting Highlights
WASHINGTON, DC – On July 12, CMS hosted the quarterly Provider Compliance Focus Group meeting at their headquarters in Baltimore. CMS presented on several topics, including: telehealth, DaVinci/DRLS/HL7, and TPE. In their TPE presentation, CMS shared that over 420,000 claims have been reviewed between October 2017-March 2019, and about half of these claims have been paid. There were 21,000 providers and suppliers that participated in TPE and of that, 16,000 were released from further audits.
CMS also provided some trends regarding companies who have failed all three rounds of TPE. Of the companies that were referred to CMS after Round 3 failure, CMS shared that conducting an additional round of TPE has been the most common scenario. However, CMS has also sent companies for RAC audits and for potential revocations.
See CMS’ presentation slides from the meeting here. The next Provider Compliance Focus Group meeting will be held in October.