NHIA Comments on CMS Home Health Proposed Rule

CMS/Medicare

ALEXANDRIA, Virginia—The National Home Infusion Association (NHIA), a trade association representing infusion companies and providers, commented on a proposed rule on Medicare home health (HH) programs from the Center for Medicare and Medicaid Services (CMS). 

The proposed rule, “Medicare Program; Calendar Year 2025 Home Health Prospective Payment System Rate Update; HH Quality Reporting Program Requirements; HH Value-Based Purchasing Expanded Model Requirements; Home Intravenous Immune Globulin (IVIG) Items and Services Rate Update; and Other Medicare Policies,” was published by CMS on July 3, 2024.

The comments and recommendations from NHIA are described below:

HIT Services

  1. CMS should remove the in-person requirement for payment under the current HIT services benefit and ensure that home infusion providers are reimbursed for each day the patient receives an infusion medication, consistent with the intent of the 21st Century Cures Act and with the practices of other payors.
  2. CMS should continue to issue the HIT Monitoring Report on an annual basis.

Home IVIG Services Benefit

  1. NHIA requests that CMS study, and base the payment allowance on, the unique home infusion pharmacy infrastructure and all professional services required to deliver IVIG in the home environment.
  2. NHIA requests CMS publish an annual report on the benefit, similar to the HIT Monitoring Report.

NHIA said it believes CMS and the HIT industry can work together to fix the Medicare HIT benefit for Medicare beneficiaries. 

NHIA represents infusion companies that provide in-home infusion therapy to patients, as well as manufacturers and suppliers of infusion and specialty pharmacy products. The company’s comment on the proposed rule expresses concerns related to Medicare beneficiaries’ access to the home infusion therapy (HIT) services benefit. The company said that while the proposed rule does not mention the home infusion therapy services benefit, it is committed to continuing to advocate for beneficiary access to these critical services.

NHIA’s full detailed recommendations on the proposed rule can be found here. 

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