AAHomecare Unveils Oxygen Overhaul Plan

ARLINGTON, Va. — Late Friday, the American Association
for Homecare released details of a sweeping reform plan to make
oxygen therapy “a more patient-centered benefit” under
Medicare.

The plan would change the legal status of oxygen companies from
“suppliers” to “providers” in recognition of the services provided
to beneficiaries, remove oxygen from competitive bidding and
eliminate the 36-month cap.

AAHomecare, the Coalition for Quality Respiratory Care and other
oxygen stakeholders have spent months hammering out details of the
plan with the aid of Leslie Norwalk, former CMS acting
administrator, who has been working to develop a reform proposal as
a consultant for the oxygen sector.

On Wednesday, the association gathered representatives of the
industry’s preeminent associations and organizaions to discuss the
reform plan. More than 30 groups were represented at the Jan. 7
meeting, including the CQRC, a coalition of many of the nation’s
largest oxygen manufacturers and providers; The Med Group,
Lubbock, Texas; VGM, Waterloo, Iowa; and 13 state and regional HME
associations.

But to reshape the home oxygen benefit, AAHomecare said,
Congress will have to enact legislation.

In a statement about the proposal released shortly before 5 p.m.
Friday, AAHomecare said given severe federal budget pressures, the
plan is designed to be budget-neutral, meaning Medicare’s net total
payments for oxygen would neither increase nor decrease.

“That also means that payments may go up or down for each
provider depending on the mix of patients but the overall financial
impact in terms of government spending would be flat. This result
is vastly preferable to continued reimbursement cuts year after
year, which will decimate the nation’s infrastructure of home
oxygen providers,” the association said.

Here is the association’s overview of the reform proposal, with
details following:

Overview of Oxygen Reform

• Changes status of oxygen entities from “suppliers” to
  “providers” in recognition of the services provided
• Exempts oxygen from Medicare’s competitive bidding program
• Repeals the 36-month oxygen cap
• The reformed benefit would reimburse providers for required
  patient services as well as for equipment and for necessary
  supplies in a bundled payment.
• Quality of care will be measured and rewarded per guidance of a
  Home Oxygen Therapy Advisory Committee.

Required Patient Services under the Reformed Oxygen
Benefit

Medicare would identify and recognize services that home oxygen
providers currently furnish, but which are not currently recognized
under the oxygen benefit:

1. Patient evaluation and care planning
2. Beneficiary/caregiver education
3. 24-hour on-call service coverage
4. Patient education and assistance when necessary for infection
   control
5. Appropriate home oxygen equipment and regular delivery of
   oxygen content
6. Concentration level and flow rate checks, filter changing and
   cleaning, assurance of the integrity of alarms and back-up oxygen
   systems
7. Visits by trained personnel to evaluate all aspects of the
   service
8. Document exception reporting when changes occur in patient
   compliance
9. Equipment serving
10. Reinforcement of appropriate equipment maintenance practices
    and performance

Requirements for Providers

• Employ appropriately trained clinical personnel according to
  state requirements
• Provide covered services under direction of licensed clinical
  professionals pursuant to physicians’ orders
• Obtain accreditation from an accrediting body that has been in
  business at least three years
• Comply with Medicare supplier enrollment regulations

Case-Mix Adjusted Reimbursement Rates

• Rates will receive annual updates.
• Rates will be adjusted for outlier payments and geographic wage
  index.
• Rates will be subject to periodic rebasing and a transition
  period.
• Rates will be adjusted based on factors such as ambulation
  level, liter flow, modality (liquid or OGPE), and mental
  acuity.

Retesting Requirement

• Home oxygen providers would facilitate retesting for certain
  Medicare beneficiaries who are prescribed oxygen after hospital
  discharge.
• Retesting would not apply to patients with certain chronic
  conditions such as COPD, emphysema, obstructive chronic bronchitis,
  brochiectasis, pulmonary fibrosis, and Alpha-1 antitrypsin
  deficiency.
• Data would go directly to a physician or independent diagnostic
  testing facility.

According to AAHomecare President Tyler Wilson, “Only
fundamental reform of the oxygen benefit in Medicare will give home
care providers real relief from the seemingly endless cycle of
payment cuts and preserve the level of services that oxygen
patients deserve and require.”

To push for legislation that incorporates the reforms,
AAHomecare has scheduled a Washington fly-in Feb. 11, “Homecare on
Capitol Hill Day,” to deliver specifics about the oxygen plan to
federal legislators. For information, see the AAHomecare Web site
at www.aahomecare.org.