WASHINGTON, DC – AAHomecare recently submitted comments to the DMEPOS Proposed Rule (CMS-1738-P). In the letter, AAHomecare included the following recommendations:
Rates in former CBAs should be based on a 90-10 blended payment formula. The 90 percent should be based on the current payment rates in former CBAs, and the 10 percent should be based on the 2015 unadjusted fee schedule.
Rates in non-rural, non-CBAs should be based on a 75-25 blended payment formula. The 75 percent portion should be based on the current rates in former CBAs, and the 25 percent portion of the blended payment formula should be based on the unadjusted fee schedule.
CMS should eliminate its proposed limit on the number of times an applicant can re-submit applications for new or revised Level II HCPCS codes, as long as the applicant includes new data/information to support the request.
CMS should add to its HCPCS code panel representatives from state Medicaid programs, and or a representative from the National Association of Medicaid Directors, and representatives of commercial payers. CMS should also rely on the outside clinical experts, for example, those it has established through MEDCAC.
We recommend that CMS incorporate into its HCPCS code application process a public notice and comment for its gap-filling and comparability analyses after a positive preliminary HCPCS code decision, to allow for both public input and for CMS to publicize the information it uses in making these payment determinations
CMS should permanently exempt accessories used with complex manual wheelchairs from competitive bid program-derived pricing, as it did in 2017 for accessories used with complex power wheelchairs.
We generally support CMS’ proposal to expand coverage to adjunctive Continuous Glucose Monitors (CGMs), but urge the Agency to address a number of outstanding implications, and allow for public comment on those issues.
See AAHomecare’s full comments and its summary of the proposed rule for more details. AAHomecare members and other HME stakeholders are welcome to support comments and include it as an attachment to your comment submission.
CMS is accepting comments until January 4, 2021 at https://beta.regulations.gov/document/CMS-2020-0128-0001. AAHomecare expects the final rule will be published sometime after the transition of the new Administration.
