Reviewing a Successful 2014

Substantial challenges lie ahead for the home medical equipment community in 2015, but based on our experience at AAHomecare last year, we’re ready to pick up where we left off before the holiday break and continue to deliver results that improve the regulatory climate for HME providers, which in turn helps us better care for the patients we serve. The multiple audit contractors that HME companies have to contend with aren’t disappearing any time soon, but we’ve made significant progress on both the regulatory and legislative fronts in this area. We have helped raise the visibility of the stifling backlog of audits awaiting adjudication at the Administrative Law Judge (ALJ) level and provided guidance to CMS and the Office of Medicare Hearings and Appeals (OMHA) on how to reduce needless appeals, including recommendations to adjust current contractor and claims processes to prevent appeals from proceeding to the ALJ level, as well as comments on the statistical sampling and conference facilitation settlement options. We also saw the introduction of HR 5083, the Audit Improvement and Reform Act, which would alleviate the paperwork burdens on suppliers, reinstate clinical inference into the review process, exclude providers with low error rates from some or all audits over a period of time and establish education and outreach programs for ordering providers. While we were not able to pass HR 5083 in this year’s session, the bill was the most significant audit-related legislation introduced in recent memory. Now that we have this issue on Congress’ radar, we look to get a similar bill re-introduced this year. In the power mobility space, CMS accepted our recommendation to move a specific accessory for complex power wheelchairs from the Capped Rental to the Routinely Purchased category. We are going to use this as a starting point for moving other codes, and to show the need for consistency. It simply does not make sense to rent replacement parts on a chair that is beneficiary-owned. We also convinced CMS to release useful guidance on supplier documentation requirements for repair claims. We scored important gains on issues related to face-to-face exam requirements, including allowing physicians to use a template to document these exams and clarifying that the same physician does not have to perform the exam and complete the written order prior to delivery. Our efforts in the respiratory segment helped stop semiautomated RAC audits for CPAP devices in Jurisdiction C. We also worked with CMS to clarify oximetry test requirements for oxygen therapy. Our most significant investment this year was the launch of the Save My Medical Supplies campaign, encompassing an active web and social media presence anchored by savemymedicalsupplies.org. The campaign, which gives a voice to individual consumers and users of HME, has generated more than 7,000 letters to Congress on the competitive bidding issue and helped us tap into new voices and advocates among the people who depend on our products, and we expect this year’s success to serve as a springboard to expanding our efforts to harness the power and passion of the ever-growing population who depends on HME to help advocate for our industry. And finally, there’s been unprecedented activity on the competitive bidding front in 2014, as CMS looks to expand single payment amounts into rural areas in 2015. As we put together this column for print, we’re in the final week of the 113th Congress, having secured strong bipartisan endorsement of H.R. 4920, legislation that would remove speculative and non-licensed bidders from the program, and helping build support for a just-introduced Senate companion bill. Whatever result comes out of this session, you can be sure that we will not rest until serious deficiencies with this program are fairly resolved. I want to thank the hundreds of companies, large and small, that have made an investment in AAHomecare through their membership and service on our various councils and workgroups; you have furnished energy, guidance and resources needed to make these accomplishments possible. And, for the companies that aren’t yet part of AAHomecare, I’d like to invite you aboard so we can present an even stronger catalog of success at this time next year. Join us!