WASHINGTON, DC – As noted last week, the House and Senate passed legislation that keeps across-the-board 4% PAYGO cuts to Medicare reimbursement from taking effect in 2022 and extends the pause on 2% sequestration cuts through the first quarter of 2022. President Biden signed the measure into law on Friday. Stopping the PAYGO cuts will keep $429 million more in HME suppliers’ coffers in 2022.
In addition, delaying full implementation of the 2% sequester will prevent an additional $80 million in cuts for now, although that $80 million measure of relief will be balanced by a temporary increase in the sequester in 2030.
Averting the PAYGO cuts and long moratorium on the 2% Medicare sequester dating back to April 2020, along with the other major relief we’ve advocated for since the onset of the COVID-19 Public Health Emergency, allow the HME community to continue to provide high quality care and lessen the stress on hospitals, nursing facilities, and clinicians during the ongoing pandemic.
Next Challenge: Responding to the DME Rule
HME advocates made sure that Congress understood the critical need to stop the PAYGO cuts from going into effect through our virtual legislative conference in September, repeated follow-ups with Congressional staff, and more than 6,700 emails to The Hill through our Action Center.
Now the HME community waits for a long-anticipated DME Final Rule. AAHomecare and other HME stakeholders have made the case in comments and direct outreach to CMS officials to include these measures in the rule:
- Permanent adoption of 50-50 blended rates for rural areas.
- Permanent adoption of 75-25 blended rates for other non-CBAs.
- Provide a meaningful positive adjustment for rates on former CBAs that reflects the market realities faced by the HME community.
Sending a Message that Can’t Be Ignored
While we hope CMS will incorporate these measures into the Final Rule, AAHomecare has been working with our champions on Capitol Hill to address these issues through legislation, if needed. Once CMS reveals their plans for reimbursements going forward, HME advocates will need to make a strong and sustained case for realistic, sustainable, market-driven rates.
AAHomecare and other leaders in our industry will provide talking points, data, and guidance on how to send a message that the House and Senate can’t ignore – and we’ll need every segment of the HME community on board! Get ready to fight – and win – in 2022.
AAHomecare Shares 2022 Fee Schedule Analysis for Top 25 DME Items
AAHomecare’s analysis of the top 25 DME items shows the following average rate increases for CY 2022 compared to rates currently in place:
• CBP items in former CBAs: +5%;
• CBP items in rural areas: +4.9%; and
• CBP items in non-rural areas: +5.1%
The CY 2022 CPI-U increase is applied to the current public health emergency (PHE) relief rates of 75/25 blended rates in non-rural areas and 50/50 blended rates in rural areas. The 2022 DME rates also reflects the removal of the oxygen budget neutrality offset that was implemented in April 2021.
You can download AAHomecare’s top 25 HCPCS codes analysis (Excel spreadsheets) here:
- CY 2022 Top 25 DME Items Former CBA Fee Schedule Analysis
- CY 2022 Top 25 DME Items Rural and Non-Rural Fee Schedule Analysis
SMRC and RAC Post New Audits Including Surgical Dressings, Enteral Nutrition, and Parenteral Nutrition
WASHINGTON, DC – The Supplemental Medical Review Contractor (SMRC) recently posted a new audit for surgical dressings. The review will be on all HCPCS listed in the Surgical Dressings LCD (L33831) for claims with a date of service (DOS) between January 1, 2019- December 31, 2019. The SMRC notes that surgical dressings rank as the one of the top four product categories with the highest improper payment rate. The 2019 Comprehensive Error Rate Testing (CERT) improper payment rate for surgical dressing was 62.8%.
You can find more information on this review here.
In addition, the Recovery Audit Program contractor (RAC), Performant Recovery, posted two new approved audits on Enteral Nutrition Therapy and Parenteral Nutrition Therapy last week. Both are complex reviews and the RAC will be reviewing whether the therapies were reasonable and necessary. These reviews will affect claims with a date of service on or after September 5, 2021.
You can find additional information on the reviews at the links and the list of affected HCPCS codes:
- Enteral Nutrition Therapy with Dates of Service on/after September 5 2021: Medical Necessity and Documentation Requirements: B4034, B4035, B4036, B4081, B4082, B4083, B4087, B4088, B4149, B4150, B4152, B4153, B4154, B4155, B4157, B4158, B4159, B4160, B4161, B4162, B9002
- Parenteral Nutrition Therapy with Dates of Service on/after September 5, 2021: Medical Necessity and Documentation Requirements: B4164, B4168, B4172, B4176, B4178, B4180, B4185, B4189, B4193, B4197, B4199, B4216, B4220, B4222, B4224, B5000, B5100, B5200