Home Health & Hospice Week

Proposed policy encourages use of durable NPWT instead of disposable.

If a Medicare proposal on negative pressure wound therapy gets finalized as-is, both home health agencies and Medicare will pay the price.

Why? In its 2017 Home Health Prospective Payment System proposed rule, the Centers for Medicare & Medicaid Services wants to require home health agencies to bill on TOB 34x for NPWT devices, which would include the visits associated with them. Alaw passed earlier this year requires the agency to pay separately for disposable NPWT devices, CMS noted in the proposed rule published in the July 5 Federal Register.

Most commenters on the proposed rule liked the idea of separate disposable NPWT payment — but not excluding NPWT-related visits from HH PPS (32x) claims.

“We urge CMS to ensure that HHAs are not adversely affected by its implementation,” exhorted the American Physical Therapy Association in its comment letter on the rule. The change would underpay HHAs for services and place additional documentation and billing burdens on them (see story, p. 278).

Underpayment would be intensified when excluding NPWT visits from 32x claims would bump an episode down to a Low Payment Utilization Adjustment episode, noted the National Association for Home Care & Hospice in its comment letter. Excluding visits could also lead to patients being declared totally ineligible for the home care benefit, NAHC feared.

The proposal also introduces confusion on how to bill a maintenance visit related to NPWT. Under the proposed policy, “the home health agency would not be able to use bill 34x for the maintenance visit because this code would already have been billed on an initial visit,” worried the Visiting Nurse Associations of America in its comment letter. “To bill a maintenance visit using 34x would effectively pay the home health agency twice for the same disposable NPWT device.”

Due to the reimbursement and operational problems, the proposal would actually encourage the use of pricier NPWT devices under the durable med ical equipment benefit, warned Lafayette, La.-based

LHC Group Inc. in its comment letter. “By ignoring the service element of providing the NPWT device, CMS is encouraging providers to continue to provide DME equipment for wound therapy,” the chain said.

Incentivizing the use of DME NPWT devices has an impact beyond reimbursement, noted UnityPoint Health in its comment letter on the rule.

The proposed policy fails “to recognize that a patient’s condition may warrant the use of a disposable NPWT device until an outpatient approved NPWT device can be used,” says the Iowa-based health system. “Presently, HHAs are a predominant provider for this service. Current practice patterns reflect funding limitations (i.e. hospitals and outpatient offices do not get reimbursed for the management or application of disposable NPWT devices) and the limited time capacity of physician offices and wound centers to perform this type of wound care.”

The result: “Effectively, this rule embeds procedural complexity that will drive service and the use of particular devices over the judgment of a provider relating to patient care,” UnityPoint charged. “It is likely that this rule will result in service delays due to transportation barriers and/or use of devices that may not be the best suited to a patient’s condition.”

Follow Osteoporosis Drug Example, Commenters Urge

“It was the intent of Congress to put disposable NPWT on par with those non-disposable NPWT products currently being supported by CMS’s DME coverage policy,” Wound, Ostomy and Continence Nurses Society President Carolyn Watts said in the society’s comment letter on the proposed rule. “Currently, HHAs report a home health visit under Bill Type 32x to account for their travel and wound care management including the use of NPWT DME. We fail to see why CMS would not create a parallel policy for disposable NPWT as Congress intended.”

Many commenters urged CMS to do just that. The National Association for Home Care & Hospice “strongly encourages CMS to develop a method that allows a separate payment on a TOB 32x for the skilled visit associated with disposable NPWT,” the trade group said in its comment letter. “Payment for the device would be submitted on a TOB 34x.” That policy would be the same as CMS’s reimbursement policy for osteoporosis drugs, multiple commenters pointed out.

Alternatives: Commenters offered a variety of other solutions as well, however. Some suggested implementing the same procedure for disposable NPWT billing as DME NPWT billing — allowing suppliers to bill for the disposable NPWT unit and HHAs to bill for nursing visits. Another suggested upping the skilled nursing visit rate amount to cover NPWT costs and having no separate disposable NPWT unit billing.

Stay tuned: Find out whether CMS heeds the industry’s feedback when it issues the final rule, expected in late October or early November.