Respiratory Stakeholders Push Back Against CPAP Bundling Proposal

—via AAHomecare, WASHINGTON, D.C. (March 22, 2017)—As first reported in late January, CMS included bundling CPAP devices, related accessories, and services on a monthly basis for Round 2019 of competitive bidding for HME, starting with five new CBAs specific to CPAP products only. AAHomecare has been working with leading respiratory stakeholders among its membership and industry groups including AdvaMed, CQRC and VGM to study the issue and develop a unified response to enable high-quality care for beneficiaries and represent the interests of respiratory providers.

Bundling the CPAP device, consumable items, maintenance and service into a single monthly payment will cause disruption for suppliers and will provide an incentive to furnish inferior products and provide a lower quality of care to compensate for shrinking margins. Timely replacement for worn out accessories is likely to suffer, as well.

As AAHomecare and stakeholders working on the issue understand the Agency’s plans, these bundled monthly rental payments will be for the duration of a beneficiary’s medical need, in spite of the bidding program’s statutory requirements for “capped” rental and “inexpensive and other routinely purchased” equipment categories that apply to CPAP and accessories.

AAHomecare’s research into legislation and other regulations pertaining to the bidding program and Medicare reimbursement for HME leads us to conclude that CMS’s competitive bidding authority does not include the authority to engage in bundled bidding programs for CPAP or other HME products, such as power wheelchairs.

“Payment models for CPAP should not jeopardize patients’ access to the specific equipment best suited to their needs or the quality of care they receive,” said Larissa D’Andrea, Government Affairs Director for ResMed, a leading manufacturer of CPAP and other respiratory medical devices. “Bundling may also be problematic for patients: it could substantially increase copayments and out-of-pocket expenses for beneficiaries. Plus, layering untested bundled payments on top of expanded competitive bidding program rates could compound existing access challenges caused by these other cuts.”

AAHomecare and our partners in this effort will encourage CMS to explore approaches that will allow suppliers to continue to furnish high-quality equipment and take into account maintaining high patient satisfaction and better clinical outcomes for individuals who use CPAP products. We will release the full text of our forthcoming letter to CMS on the issue when it is finalized and sent to the Agency, and will continue to press the issue with CMS and on Capitol Hill.

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