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