(2005-05-15)
Last week, the Office of Inspector General (OIG) of the US Department of Health and Human Services sent a survey to a random sample of providers of inhalation drug therapies. The survey seeks information about services provided in 2003 to Medicare patients in connection with inhalation drugs administered through a nebulizer.
The information requested by the OIG in this survey could result in survey conclusions and recommendations that CMS could use in decisions related to the dispensing fee paid for inhalation drug therapy, so it is critically important that any provider that received the questionnaire respond accurately. It is critical that you capture and record all services provided to and contact made with the identified patients in order to provide support for the extensive costs incurred by pharmacies in dispensing inhalation drugs to Medicare beneficiaries. The survey requires completion of a form for each service provided to patients during 2003. However, the questionnaire does not capture all dispensing fee service categories and therefore requires additional pages to demonstrate the provision of all the unlisted services that would fall into the “other” category on the survey. For instance, the survey does not capture any after-hours or weekend services and excludes all billing activities, which omits substantial activities and services that would factor into the costs of providing and dispensing home inhalation drug therapy to Medicare patients.
Because the survey requires retrieval of documentation for 2003 services and the OIG requests responses by May 18, 2005, the American Association for Homecare (AAHomecare) recommends that each provider request that the OIG extend its deadline to June 20 to ensure they comply fully with the document and information request. Many providers store service records off-site.
AAHomecare has requested a meeting with the OIG to discuss the survey and convey its concern that the survey may not collect adequate and accurate service and cost information related to inhalation drug therapy.
Last year, AAHomecare commissioned a study by Muse and Associates of 109 pharmacies, which found the 2005 Medicare reimbursement formula based on average sales price (ASP formula) would under-reimburse the actual cost of providing and dispensing two key drug therapies (albuterol sulfate and ipratropium bromide) by $68.10 per monthly supply. AAHomecare shared with the Government Accountability Office and Centers for Medicare and Medicaid Services (CMS) information about the patient-management, pharmacy, compounding, delivery, and administrative costs of providing these drug therapies and argued the therapies cannot be provided to Medicare patients at the ASP formula without a substantial dispensing fee. Last November, CMS announced a $57 monthly dispensing fee for inhalation therapies for 2005 and a 90-day fee of $80 in the 2005 physicians' fee schedule.
CMS Releases Mobility Coverage Criteria; AAHomecare Will Continue Push to End “In-the-Home” Restriction
Last week, CMS released new national coverage criteria for mobility assistive equipment, which includes power wheelchairs and scooters. In a statement, CMS said these new criteria, which are effective immediately, “adopt a function-based determination of medical necessity. This determination looks at the ability of the beneficiary to safely accomplish mobility-related activities of daily living, such as toileting, grooming, and eating, with and without the use of mobility equipment such as a wheelchair.” The national coverage determination addresses the full range of mobility equipment from canes and walkers to power wheelchairs.
AAHomecare will continue to press for elimination of the “in-the-home restriction” for coverage of mobility assistive equipment and an expansion of the interpretation of activities of daily living (ADLs) to include mobility itself during its upcoming Washington Leadership Conference and going forward.
AAHomecare membership anticipates a meeting with CMS to clarify several issues, including documentation requirements for determination of medical necessity for mobility equipment, and to work toward appropriate implementation of this coverage policy. The Association supports CMS' general move to more functionally based clinical criteria for coverage and the long overdue elimination of the “bed-or-chair-confined criteria.” AAHomecare remains committed to working further with its membership and other stakeholders to ensure that every beneficiary in need of mobility assistive equipment receives it, every time.
For details about the NCD, see:
www.cms.hhs.gov/mcd/viewdecisionmemo.asp?id=143
AARP Study Calls for Funding for Homecare; Finds “Vast Majority” of Older Americans Want to Remain in their Home
The AARP's new study on livable communities, “Beyond 50.05, A Report to the Nation on Livable Communities,” lists funding of homecare as one of its calls to action. The report recommends funding of programs and incentives to promote homecare and other community-based services to persons of limited means.
The study also reaffirms the fact that the vast majority of people over the age of 50 want to remain in their current residence. 74 percent of Americans over the age of 50 strongly agree with the statement, “What I'd really like to do is stay in my current residence for as long as possible.” That percentage is 83 percent for those age 65 to 74 and 86 percent for those 75 and older. The data is based on a sample of more than 1,000 surveyed by AARP and Roper in 2004. AAHomecare staff attended an AARP briefing for stakeholders in Washington last week to discuss the study's findings.
Noteworthy Quote(s) from New England
“NEMED looks forward to working with our national associations and other groups to demonstrate the value of homecare. It's important for the industry to speak with a united voice-now more than ever. As Benjamin Franklin once said, ‘We must all hang together, or assuredly, we shall all hang separately.'”
- Karyn Estrella, Executive Director, New England Medical Equipment Dealers association, quoted in a bylined column in May issue of HME News.
Make Your Voice Heard at AAHomecare Washington Conference, June 7-10
Hundreds of homecare providers from across the U.S. have registered for the AAHomecare Washington Leadership Conference at the JW Marriott June 7 through June 10. Meetings with Members of Congress are being scheduled for Wednesday, June 8. Come to Washington to lobby, network, learn, and get a full dose of advocacy in action. Bring the family.
See details and register today at AAHomecare's website, http://www.aahomecare.org
Michael Reinemer, VP, Communications
American Association for Homecare
625 Slaters Lane, Suite 200
Alexandria, VA 22314-1171 703-535-1881
http://www.aahomecare.org