Page 19 - HME Business, January/February 2022

“The 90 percent should be based on the current single payment amounts in former CBAs, and the 10 percent should be based on the 2015 unadjusted fee schedule,” Brummett explains.
• 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 unad- justed fee schedule,” Brummett says. “The industry currently has this blend because of the pandemic, but it ends when the public health emergency ends. ... Unfortunately, it seems likely that the PHE is going to be extended, and most likely through 2022,” she adds.AAHomecare also made some recommendations regarding product coding, complex rehab, and diabetic supplies:
• 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/infor- mation 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 commer- cial payers. CMS should also rely on outside clinical experts. For example, those it has established through MEDCAC.
• AAHomecare recommended 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.
• AAHomecare generally supported CMS’ proposal to expand coverage to adjunctive Continuous Glucose Monitors (CGMs) but urged the Agency to address a number of outstanding implica- tions and allow for public comment on those issues.
A LONG DELAY
The comments were submitted and then began the waiting game. HME industry and DMEPOS suppliers waited for CMS to release the final rule, but nothing happened for several months of 2021.
“The change in administration caused many rules to be held up as HHS and CMS staff were replaced,” Brummett explains. “The new administration took their time to review and most likely adjust the content which caused the delay in publication.”
However, AAHomecare worked to move things along. When it was finally able to host a virtual version of its annual Washington Legislative Conference in September 2021, it circulated a House congressional sign-on letter calling for the final rule. Introduced into the House by Reps. Cathy McMorris Rodgers (R-Wash.) and Paul Tonko (D-N.Y.), the letter urged the leadership of CMS and HHS to finalize the DME rule and to adopt the additional rate provisions. The letter garnered 95 signatures from various House lawmakers.
Less than a month later, in late October 2021, after the House sign-on letter was sent to CMS and HHS, CMS’s DME final payment rule was moved to the Office of Management and Budget (OMB)
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