Home Health & Hospice Week

Don’t miss a number of mainly non-home health, non-hospice provisions included in the latest home health proposed payment rule.

The Centers for Medicare & Medicaid Services proposes implementing regulations for new lymphedema equipment coverage in the rule. “The CAA, 2023 establishes a Medicare Part B benefit for standard and custom-fitted gradient compression garments and other compression treatment items, for the treatment of lymphedema that are prescribed by an authorized practitioner,” CMS explains in its rule fact sheet.

“This rule would address the scope of the new benefit by defining what constitutes a standard- or custom-fitted gradient compression garment and identifying other compression items used for the treatment of lymphedema that would fall under the new benefit category, beginning January 1, 2024,” CMS says. The regulation also gets into details including HCPCS codes, payment methodology, and rate-setting.

“Due in part to significant #PTAdvovacy from APTA, CMS has proposed a new benefit category that will provide coverage for lymphedema compression garments and services, coverage that could affect 3+ million Medicare beneficiaries,” the American Physical Therapy Association celebrates in a statement on social media.

“Coverage for Lymphedema therapy items will be provided under the Medicare durable medical equipment benefit, and therefore will not have any negative financial impact for home health agencies since items of DME are excluded from the Medicare home health consolidated billing rules,” the National Association for Home Care & Hospice explains in its rule analysis.

The rule also proposes to “codify statutory requirements for disposable negative pressure wound therapy,” CMS says in its rule fact sheet.

The law requires CMS to change how calculates the payment amount, switching from “equal to the amount of the payment that would be made under the Medicare Hospital OPPS using the CPT codes 97607 and 97608 and include[ing] the professional service as well as the furnishing of the device” to “equal to the supply price used to determine the relative value for the service under the Physician Fee Schedule (PFS) … updated by the specified adjustment described in subparagraph (B) for such year,” and after that “equal to the payment amount established for the device in the previous year, updated by the specified adjustment described in subparagraph (B) for such year.”

The takeaway: “Payment for such nursing or therapy services would now be made under the prospective payment system … the HH PPS, and is no longer separately billable,” CMS explains.

And CMS changes billing for the devices. “Beginning in CY 2024 … claims for the separate payment amount of an applicable dNPWT device would now be accepted and processed on claims submitted using the type of bill that is most commonly used by home health agencies to bill services under a home health plan of care (TOB 32X),” the rule says. “Claims with a date of service on or after January 1, 2024 for an applicable dNPWT device will no longer be submitted on TOB 34X,” it specifies.

Another rule provision proposes to put in place some infusion requirements.

“As required under … the CAA, 2023, CMS is proposing regulations to implement coverage and payment of items and services related to administration of [Home Intravenous Immune Globulin] in a patient’s home for a patient with a diagnosed primary immune deficiency disease (PIDD),” CMS explains in its fact sheet.

Old way: “Currently, Medicare pays for the IVIG product using the average sales price (ASP) methodology, and the items and services needed for in-home administration of IVIG for the treatment of PIDD are paid under a Medicare demonstration program,” CMS elaborates. “This demonstration program will end on December 31, 2023.”

New way: “The CAA, 2023 establishes permanent coverage and payment of the items and services needed for in-home administration beginning on January 1, 2024,” CMS says.

Finally, the rule contains two other durable medical equipment-related provisions:

• Auto-shipped refills. “In response to concerns related to auto-shipments and delivery of DMEPOS supplies that may no longer be needed or not needed at the same level of frequency/ volume, CMS … [is] proposing to require documentation indicating that the beneficiary confirmed the need for the refill within the 30-day period prior to the end of the current supply” and “that delivery of DMEPOS items (that is, date of service) be no sooner than 10 calendar days before the expected end of the current supply,” CMS says in the fact sheet.
• Brace definition. The rule proposes to codify the “longstanding Medicare definition of brace to provide clarification on the scope of the Medicare Part B benefit for leg, arm, back, and neck braces and as a result, would classify certain exoskeleton-type devices as braces for Medicare payment purposes,” CMS says.