WASHINGTON, DC – As AAHomecare noted last week, CMS has published the CY 2020 Medicare DMEPOS Fee Schedule.  Per the MLN Matters article on the fee schedule update, we see the following changes with the reimbursement rates:

Former CB Areas
Oxygen: ~2% increase
Other DMEPOS included in CB: ~2.4% increase

Non-CBA/Non-Rural
Oxygen: ~3.5% increase
Other DMEPOS included in CB: ~1.6% increase

Non-CBA/Rural:
Oxygen: ~1.5% increase
Other DMEPOS included in CB: ~1.1% increase

Diabetic Testing Supplies
Mail order: ~2.4% increase
Non-mail order: no adjustments

Items not included in CB program: ~0.9% increase

AAHomecare analyzed the top 25 HCPCS codes for each region and former CBA and found the rates to be consistent with CMS’ explanation of the fee schedule updates.  See our region-by-region analysis for additional perspective:

• Far West – CA, OR, NV, WA
• Great Lakes – IL, IN, MI, OH, WI
• Mideast – DE, DC, MD, NJ, NY, PA
• New England – CT, ME, MA, NH, RI, VT
• Plains – IA ,KS, MN, MO, NE, ND, SD
• Rocky Mountains – CO, ID, MT, UT, WY
• Southeast – AL, AR, FL, GA, KY, LA, MS, NC, SC, TN, VA, WV
• Southwest – AZ, NM, OK, TX
• Former CBAs

AAHomecare Comments on CBP Survey

WASHINGTON, DC – Last week, AAHomecare submitted comments to CMS’ request for comments on Competitive Bidding Surveys. As we noted last week, CMS is soliciting comments on questions to include in surveys to monitor the Competitive Bidding Program.

CMS is interested in surveying key stakeholders such as beneficiaries, contract suppliers, and discharge planners. In addition to providing stakeholder specific sample questions and a list of organizations for CMS to contact in dispersing the surveys, we provided some recommendations on how to contact stakeholders and requested CMS to be transparent with the results.

You can read AAHomecare’s comments and sample questions below:

• AAHomecare Comments
• Supplier Survey Sample Questions
• Case Manager Survey Sample Questions
• Beneficiary Survey Sample Questions
• NIV Survey Questions (baseline)
• NIV Survey Questions (post Round 2021 implementation)

We encourage membership to provide feedback on this opportunity, and we welcome sharing AAHomecare’s comments/questions. Comments are due this Friday, December 20th. See more details in CMS’ announcement.

AAHomecare Preparing Comments on Anti-Kickback Statue and Stark Law Proposed Rules

WASHINGTON, DC – In October, CMS and the HHS Office of Inspector General (OIG) simultaneously published proposed rules on updating regulations based on the Stark Law and Anti-Kickback Statute (AKS) with the goal of improving patient care coordination and reducing regulatory burden. AAHomecare is currently in the process of developing feedback; below are some highlights from our forthcoming comments:

AKS Comments (HHS OIG):

• AAHomecare disagrees with the exclusion of DMEPOS suppliers from the definition of “VBE participant.” AAHomecare urges the OIG not to exclude DMEPOS suppliers from the VBE participant category.
• AAHomecare supports the goal of modifying and expanding the nominal value exception to facilitate coordination of care.

Stark Law Comments (CMS): 

• AAHomecare disagrees that physicians’ arrangements with DMEPOS suppliers should be ineligible as Value-Based Arrangements. AAHomecare urges CMS to include physicians’ arrangements with DMEPOS suppliers in VBAs.
• AAHomecare supports the goal of modifying and expanding the Stark exceptions to facilitate coordination of care.

Comments to both rules are due on December 31. See the full proposed rules and accompanying fact sheets for more perspective:

• HHS OIG proposed rule and factsheet on AKS
• CMS proposed rule and factsheet on Stark Law