Welcome

Welcome

Tom Ryan

President and CEO

@TomRyanHME

About

Introduction

Quote

“Our industry is changing. We need

leaders who know how to fight the tough

battles, and who are also ready to shape the future of

homecare…”

PowerofHomecare.com

Unifying Industry Grassroots Efforts

• Brand Neutral – One Umbrella for HME Industry Grassroots

• Clear and Consistent• State Association Endorsed• More than 4,000 Letters Since Launch in Mid-

July• Supported with Earned and Social Media

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Your Team in DC

Public Policy

PUBLIC POLICY

Jay Witter

Senior Vice President, Public Policy

Binding Bids are Now Law

2015 Binding Bids Bills S. 148 and H.R. 248

Medicare DME Competitive Bidding Improvement Act

Amends title XVIII (Medicare) of the Social Security Act to require state licensure and a bid and surety bond of at least $50,000 for each area for bidding entities under the Medicare durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) competitive acquisition program.

***Passed Into Law April 16 2015***

Thank you to Reps.

Thanks to Reps. Tiberi (R-Ohio) and Larson (D-Conn.) and

Sens. Portman (R-Ohio) and Cardin (D-Md.) for their leadership.

Thank you to the many HME providers, state association leaders and others who worked to keep Congress

educated about the ill-effects of this program in their localities, without them this bill would never have become

law.

Medicare DME Competitive Bidding Improvement Act

• Included in the Medicare Access and CHIP Reauthorization Act• Will require bidders to submit bid bond for each CBA, before

submitting bid• Require proof of licensure before a supplier can submit a bid• Elevates to federal law compliance with state law requirement• Effective when?

• CMS can make bid bond a requirement for contracts beginning 2017

• CMS must make it a requirement for contracts beginning 2019 and after

• Why delay? Cost issue!• State law requirement effective upon enactment

Industry Focus for the 114th Congress

• Competitive Bidding/Expansion to Non-Bid Areas

• MPP Demo• Audit Reform Legislation• Prior Authorization• CRT Legislation

Competitive Bidding Fixes

Short term: Working to mitigate the rural rollout of Competitive Bidding set to begin in 2016. The current focus is to phase in the nationwide rollout over a four year period instead of current statute of a five month phase in. Mitigating this program that truly stamps out competition is key for allowing the long-term fix to replace competitive bidding entirely.

Intermediate term: There have been positive steps taken by Congress through industry initiatives to make the necessary corrections to Competitive Bidding. Binding Bid language has been signed into law that holds bidders accountable for the bid that they place. The implementation date of this change is problematic, but correction language is a simple fix that we will be working towards fixing later this year.

Long term: The most sustainable alternative to Competitive Bidding is replacing it with “The Medicare DMEPOS Market Pricing Program.” This program will change the process to a true auction system which economists & auction experts have embraced. Rep. Tom Price (R-GA) has introduced this legislation in past sessions of Congress, but now with providers engaging their members of Congress it is progressing well.

Reimbursement Cuts in Non-CB Areas

• The ACA (P.L. 111-148) included a provision that required CMS to either expand competitive bidding or make adjustment based on the bid program in non-competitive bidding areas.

• In 2014, AAHomecare indicated strong concern in comments to CMS in response to the Advance Notice of Proposed Rulemaking (ANPRM) regarding the expansion of competitive bidding rates to non-bid and rural areas.

• AAHomecare immediately began a series of regular meetings with industry leaders to discuss strategies for halting the expansion of the 2016 rate cuts.

• As always, AAHomecare was in constant communication with key Congressional committees and top CMS staff, including deputy director Sean Cavanaugh.

CMS’ Plan for Cuts in Non-CB Areas(ESRD Final Rule)

• For qualified DME items, the final rule phases in, over 6 months, a new reimbursement rate for non-competitive bidding areas.

• On January 1, 2016, the reimbursement rate for these claims (with dates of service from January 1, 2016 through June 30, 2016) will be based on 50 percent of the un-adjusted fee schedule amount and 50 percent of the adjusted fee schedule amount which will be based on the regional competitive bidding rates.

• Starting on July 1, 2016, reimbursement rate will be 100% of the adjusted fee schedule amount which will be based on regional competitive bidding rates. For example, if the unadjusted fee schedule amount on January 1, 2016 is $100.00 and the regional competitive bidding rates is $75.00, the fee schedule amount established by the ESRD rule will be $87.50. Beginning on July 1, 2016, the fee schedule established by the ESRD rule will be $75.00.

• AAHomecare is working with key members of the House and Senate to address these drastic cuts.

Providing Relief in Non-CB Areas

• Key members of Congress have indicated to AAHomecare that the HME industry must be aligned and have one clear proposal for them to support.

• As the national trade association representing the HME community, it is imperative that HME stakeholders support AAHomecare as the voice of the industry.

• Over the last four months, the association has been working behind the scenes to bring the collective weight of the industry behind a specific proposal for relief from the 2016 expansion of bid rates.

• The following legislative provisions are the result of hundreds of conversations, face-to-face meetings, spirited debate and prudent compromise with providers of all shapes and sizes, allied trade associations and leaders in Congress.

Short Term Fix in Non-CB Areas

DMEPOS Rule Relief Legislative Specifications:

For all DMEPOS, the Secretary must:

• Establish a 30 percent adjustment to address increased costs suppliers incur in non-competitive bidding areas to be applied to average regional single payment amount as determined by the methodology set forth in 42 C.F.R. 414.210(g) (79 Fed. Reg. 66120 (November 6, 2014)), as well as an update mechanism.

• Provide for a four-year phase-in of the national price adjustments to the DMEPOS fee schedule set forth in 42 C.F.R. 414.210(g) (79 Fed. Reg. 66120 (November 6, 2014)) when implementing them.

• Establish in statute the bid limit ceiling for competitive bid contracts that begin on or after January 1, 2017 at the unadjusted fee schedule payment rates as of Jan 1, 2015.

• These provisions will serve as our starting point as we move forward in our negotiations with leaders in Congress to have this language either included in future legislation or as a stand-alone piece.

Mid-term Competitive Bidding Fix

• Goal now is to move up binding bid requirement to be effective for next Round 1 bid areas bidding (2017 contracts)

• Appropriations strategy

• Means appropriated funds would be linked to requirement that CMS make binding bids effective for contracts beginning January 2017

Binding Bids Appropriations Language

H.R. 2 -Medicare Access and CHIP Reauthorization Act of 2015 (P.L. 114-10)

SEC. 522.REQUIRING BID SURETY BONDS AND STATE LICENSURE FOR ENTITIES SUBMITTING BIDS UNDER THE MEDICARE DMEPOS COMPETITIVE ACQUISITION PROGRAM.

(a)BIDSURETYBONDS.—Section 1847(a)(1) of the Social Security Act (42 U.S.C. 1395w–3(a)(1)) is amended by adding at the end the following new subparagraphs:“(G)REQUIRING BID BONDS FOR BIDDING ENTITIES.—With respect to rounds of competitions beginning under this subsection for contracts beginning not earlier than January 1, 2017, and not later than January 1, 2019, an entity may not submit a bid for a competitive acquisition area unless, as of the deadline for bid submission, the entity has obtained (and provided the Secretary with proof of having obtained) a bid surety bond (in this paragraph referred to as a ‘bid bond’) in a form specified by the Secretary consistent with subparagraph (H) and in an amount that is not less than $50,000 and not more than $100,000 for each competitive acquisition area in which the entity submits the bid._________________________________________________________

Proposed Appropriations Language to Require CMS to Implement the Surety Bond Requirement for Contracts starting on January 1, 2017

The Secretary shall use appropriated funds for the Centers for Medicare and Medicaid Services to Implement the DMEPOS bid surety bonds requirement in section 1847(a)(1)(G) of the Social Security Act for contacts beginning on January 1, 2017.

Long Term: Alternative to Competitive Bidding- Market Pricing Program (MPP)

• AAHomecare examined ways to fix the current program and explored alternative approaches to finding market-based prices for reimbursement.

• AAHomecare worked with state leaders, economists, and key members of Congress to develop the Market Pricing Program.

• MPP replaces competitive bidding based-problems that economists and auction experts identified in the current program.

• On April 24, 2013, Reps. Tom Price (R-GA) and John Larson (D-CT) introduced the Medicare DMEPOS Market Pricing Program Act of 2013 (H.R 1717).

• No CBO Score – Dr. Price is working on a MPP demonstration project to prove cost effectiveness of the alternative bid program. This will be the long term solution to current bid problems.

Bid Rate Expansion to Medicaid

• AAHomecare was informed that the expansion of bid rates to Medicaid was considered inevitable as the influences pushing the passage of the Cures bill needed these cuts to pay for the components of the legislation.

• However, AAHomecare continued working to educate lawmakers about the consequences of this provision. A full halt of the cuts was the first step in the negotiating framework, but AAHomecare and allied lawmakers were pressed to look at alternate solutions.

• AAHomecare managed to negotiate a delay of the cuts back to 2020 from the original start of 2016, thus reducing the score to $2.8 million.

Bid Rate Expansion to Medicaid

• As part of these discussions, the Energy and Commerce Committee asked for a budget neutral proposal that would help improve the HME benefit.

• Since a nationwide prior authorization process would help address audit problems, legislation was suggested that would exempt claims from audits that receive prior authorization.

• AAHomecare is working to have prior authorization language added to the Cures Bill before it reaches the House floor vote.

• AAHomecare will continue to defend against the inclusion of these cuts to Medicaid HME rates in any future iterations of this bill.

• E&C Chair Fred Upton (R-Mich.) is not optimistic about the bill making it through the other chamber in its entirety. “The Senate's never going to pass a bill this big, we know that,” said Upton. Upton noted he is looking for the Senate to pass “an innovative medicine piece” or something a little bit broader.

Bid Rate Expansion to Medicaid

• The House Energy and Commerce Committee unanimously passed the 21st Century Cures legislation, the goal of which is to foster healthcare innovation.

• The bipartisan support reflected in the 51-0 vote in favor of the bill came after lawmakers hashed out an agreement on ways to offset its estimated $13 billion cost.

• While the Cures bill has strong support in the House, it does not appear to have the support needed to pass in the Senate.

• AAHomecare is now meeting with Senate office to discuss concerns related to these cuts.

• Providers should contact their Senators and indicate what these cuts will do to Medicaid patients.

Prior Authorization Priorities

• Work with House and Senate on legislative language to make the PMD Demo permanent and nationwide.

• Work with House and Senate on the introduction of legislation to create a prior approval process for DME.

• This legislation exempts suppliers for audits if they receive prior approval. The legislation also includes patient and supplier protections to ensure the process works efficiently.

Prior Authorization – PMD

• AAHomecare has been working with Rep GT Thompson on legislation to make the Power Mobility Project permanent and nationwide

• Require the Secretary to make permanent the PMD Prior Authorization Demonstration; expand to all power mobility devices and include accessories and options; and begin expanding the PMD Prior Authorization nationally for initial claims for reimbursement under this title for all power mobility devices, accessories, and options.

• The House Energy and Commerce Committee passed language in the 21th Century Cures bill that would extend the demo and include accessories.

• Because of the Congressional pressure, CMS issued a notice that it will extend the PMD demo by 3 years.

Prior Authorization – Other DME Items

• Legislation to create prior authorization for other DME items. Rep. Marsha Blackburn introduced legislation (H.R. 2437) that would create a prior authorization process for other DME items.

• The Secretary shall begin the process to develop and implement a prior authorization process for certain durable medical equipment, prosthetics, orthotics, and supplies. A claim for an item of durable medical equipment, a prosthetic, an orthotic, or a supply that has received prior approval through the prior authorization process shall be exempt from subsequent pre- and post-payment audits and only subject to audits for systematic fraud and abuse.

Audit Reform Legislation Priorities

• Working for the reintroduction of the AIR Act (Reps. Ellmers and Duckworth)

• Working with W&Ms Committee to include AIR Act provisions in committee bill

• Working for the introduction of Senate Air Act companion bill

• Working with SFC on audit hearing and legislation

The Audit Reform and Improvement Act (AIR Act)

• Rep. Ellmers (R-N.C.) and Rep. Duckworth (D-Ill.)

• Create an improper payment outreach and education program• In order to reduce improper payments under this title, each Medicare

administrative contractor shall establish and have in place an effective improper payment outreach and education program for physicians, referral agents of services and DME suppliers.

• Reduce error rates by targeting audits by Medicare audit contractors withrespect to high error DME suppliers identified.

• Reinstate clinical inference and clinical judgment in the audit process.

• Limit documentation look-back periods to 3 years.

• Require application of timely filing limits to claims subject to payment

• Allows for a timely filing over-ride by the DME MACs for any claims related to aninitial claim that is subject to a prepayment or RAC post payment audit.

• Require the Secretary to provide a 6 month grace period for policy changes or clarifications for DMEPOS audit requirements.

Broad Support for the AIR Act – Supporting Organizations:

• American Association for Homecare (AAHomecare)

• National Coalition for Assistive and Rehab Technology (NCART)

• American Podiatric Medical Association (APMA)

• National Home Infusion Association (NHIA)

• National Association for Medical Direction of Respiratory Care (NAMDRC)

• American Orthotic & Prosthetic Association (AOPA)

• American Association for Respiratory Care (AARC)

• Advanced Medical Technology Association (AdvaMed)

• The VGM Group

• North Carolina Association of Medical Equipment Services (NCAMES)

• Association for Home and Hospice Care of North Carolina

• North Carolina Orthotics and Prosthetics Trade Association (NCOPTA)

• Georgia Association of Medical Equipment Suppliers (GAMES)

• Alabama Durable Medical Equipment Association (ADMEA)

• Arizona Medical Equipment Suppliers Association (AZMESA)

• Association for Tennessee Home Oxygen & Medical Equipment Services (ATHOMES)• Big Sky Association of Medical Equipment Services

Broad Support for the AIR Act – Supporting Organizations - Continued

• California Association of Medical Product Suppliers (CAMPS)

• Colorado Association for Medical Equipment Services (CAMES)

• Florida Alliance of Home Care Services (FAHCS)

• Florida Association of Medical Equipment Suppliers (FAMES)

• Great Lakes Home Medical Services Association

• Healthcare Association of Hawaii (HAH)

• Home Medical Equipment and Services Association of New England (HOMES)

• Jersey Association of Medical Equipment Suppliers (JAMES)

• Kentucky Medical Equipment Suppliers Association (KMESA)

• Michigan Association for Home Care

• Midwest Association for Medical Equipment Services (MAMES)

• New York Medical Equipment Providers Association (NYMEP)

• Nevada Association of Medical Products Suppliers (NAMPS)

• Ohio Association of Medical Equipment Services (OAMES)

• Pennsylvania Association of Medical Suppliers (PAMS)

• South Carolina Medical Equipment Services Association (SCMESA)

• Virginia Association for Durable Medical Equipment Companies (VADMEC)

• Wisconsin Association of Medical Equipment Services (WAMES)

• West Virginia Equipment Suppliers Association (WVMESA)

CMS to Apply CB Rates to Complex Rehab

• The CMS has announced that it will apply Competitive Bid Program (CBP) pricing to Complex Rehab wheelchair accessories effective January 1, 2016. This violates the intent of past Congressional legislation and will create significant access problems for Medicare beneficiaries and other people with disabilities. This has widespread access issues--will extend beyond Medicare to Medicaid and private health insurance programs

• 101 Members of Congress sent a “Dear Colleague” letter to CMS (co-led by Rep. Mike Kelly (R-PA) asking CMS to RESCIND their policy change and retain current payment levels. 23 Senators sent a similar letter.

• If CMS does not use their authority to rescind, Congress will need to take legislative action to prevent major access disruptions

• Legislative language is being developed to force CMS to continue to pay complex rehab accessories at the “fee schedule” amount.

Legislation to Protect CRT Accessories from Cuts

• On July 27, 2015, Congressman Lee Zeldin (R-N.Y.) introduced H.R. 3229, which clarifies Congress’ intent to exempt all complex wheelchairs and accessories from the application of competitive bid rates. Senate companion legislation – S. 2196 introduced on October 22 by Sens. Casey (D-Pa.) and Portman (R-Ohio)

• In order to protect access to this Complex Rehab equipment for Medicare beneficiaries and other people with disabilities, AAHomecare strongly urges members of Congress to support H.R. 3229 and S. 2196 and work for their passage.

CRT Separate Benefit Legislation

• A separate benefit category for Complex Rehab Technology (CRT) must be established within the Medicare program so that continued access to this critical technology and related services can be assured. These specialized products are currently included within Medicare’s broad durable medical equipment (DME) benefit category which does not provide adequate differentiation of CRT devices and prevents focused policies and safeguards.

• A separate benefit category for CRT will provide appropriate segregation to better address the unique needs of individuals with disabilities and chronic medical conditions who require these specialized products. This will allow for needed improvements in coverage policies, coding, and quality standards.

• On March 19, 2015, Reps Sensenbrenner (R-Wisc.) and Crowley (D-N.Y.) introduced H.R. 1516, legislation that will create a Separate Benefit for Complex Rehab Technology in Medicare.

2015 CRT SBC Legislation

• House bill (H.R. 1516) reintroduced March by Representatives Jim Sensenbrenner (R-Wisc.) and Joe Crowley (D-N.Y.)

• Senate bill (S. 1013) reintroduced in April by Senators Thad Cochran (R-Miss.) and Chuck Schumer (D-N.Y.)

Ensuring Access to Quality CRT Act

• Creates separate category for CRT within the Medicare DMEPOS benefit (similar to Orthotics & Prosthetics)

• Designates HCPCS specific codes as CRT and allows for creation of new codes

• Eliminates “in-the-home restriction” for CRT and adds functional considerations

• Expands clinical evaluation to all CRT mobility bases

• Increases supplier standards: “enhanced” ATP credential staff and requires repair capabilities

• Allows nursing home residents to access CRT if part of move to community residence

• Clarifies exemption of CRT from competitive bidding

Regulatory Affairs

REGULATORY AFFAIRS

Kim Brummett

Vice President, Regulatory Affairs

Vice President, Regulatory Affairs

Subbing for Kim….

HME Audit Keytracking the impacts of audits

WWW.HMEAUDITKEY.ORG

The Moment of Truth on Audits

Out there on the front lines of battle for audit reform, the overwhelming response from policymakers comes in the form of a question.

“Do you have any data to back up your statements?”

“Can you show me with numbers how this is affecting your industry?

The home medical equipment (HME) community must demonstrate the impact of audits, both in terms of volumes and overturn rates.

If we cannot accurately detail how our industry is being impacted, we will not be able to succeed in obtaining reform to the audit process.

That’s why more than a year ago AAHomecare started a project called the HME Audit Key.

What is HME Audit Key?

• Web-based survey to collect audit experience data from HME suppliers • Based on a supplier corporate organization• Quarterly data collection

o Supplier Operationso Pre-Payment Audit Activityo Post-Payment Audit Activityo Appeal Activity

• Collect quarterly beginning with audits received from October 1, 2015

Audit Key Biggest Challenges

The most common challenges reported were:

1. No time available to complete the survey

2. The company did not track audits and appeals in the manner the survey requested the information

3. Providers were unable to go back in time to the originally target start date of January 1, 2014 to quantify appeals activity

Suppliers with Net Revenue of $10.1M and Over Averaged Over 7,000 Audits with an Average Denial Rate of 34.8%

Average Number of MAC Prepayment Audits and Percent of Audits Denied By Net Revenue Range Among Participating Suppliers – through Quarter 2, 2015

Participating Supplier Net

Revenue Range

Average % Audits Denied

$0 to $1M 0.0%$1.1M to $3.5M 27.6%$3.6M to $10M 29.4%$10.1M and over 34.8%Nationwide 33.9%

Over 86% of MAC Prepayment Audits of Power Mobility Devices were Paid Upon Review

Cumulative Percent of MAC Prepayment Audits Denied Versus Paid Among Participating Suppliers by Product Category – through Quarter 2, 2015

Suppliers Appealed 80% of MAC Prepayment Denials for Respiratory Products and 92% Were Overturned

Summary of Appeal Determinations in Favor of Suppliers* by Product Category for MAC Prepayment Denials – through Quarter 2, 2015

* Includes favorable determinations at any level of appeal.

GOAL FOR SUPPLIER ATTENDEES

Visit our booth on the show floor #2210

Visit HMEAuditKey.org

Obtain an organization ID

Print out informational documents to understand data elements needed to participate

Make a difference!

AAHomecare Regulatory Goals 2015

Focus on issues associated with Medicare’s (ACA) WOPD requirements identifying issues, prioritizing and actively pursuing changes that would benefit AAH members and the beneficiaries they serve.

• Signature date on electronic orders

• WOPD Definition – 5 elements

• Date Stamp

• Face to Face Requirement Only on Initial Order

Improve/influence CERT oversight, understanding framework of CERT contractor and authority. Develop relationship with CMS oversight contacts.

• Control what we can Control

• Written Order Prior to Delivery

• Detailed Written Order

• Proof of Delivery

AAHomecare Regulatory Goals 2015

Evaluate & respond to all issues advanced notices of proposed rulesDate Letter/Comment To Whom Office3/20/15 MUE Medicare and Medicaid v2015q3_012615 Linda Dietz Correct Coding Solutions

4/28/15Paperwork Burdens Associated with Prepayment Medical Review William Parham CMS

4/29/15Paperwork Reduction Act (PRA) Review of the Medicare DMEPOS Onsite Survey Form Office of Management and Budget CMS

5/10/15 PMD Group 2 Accessories Sale versus Rental Laurence Wilson CMS

5/29/15

2015 Edition Health Information Technology (Health IT) Certification Criteria, 2015 Base Electronic Health Record (EHR) Definition, RIN 0991-AB93 Office of National Coordinator CMS

6/9/15 MUE Additions Medicaid NCCI version 2015q4 Orthotics Charleen Porter Correct Coding Solutions

6/20/15Proof of Delivery Medicare Requirements Change in Payer/Attestation Janice Hoffman CMS

6/25/15 Ventilator Code Deletion, Consolidation and Pricing Coding Comments CMS7/9/2015 Miscellaneous Code and Pricing Changes Coding Comments CMS7/27/2015 Proposed Rule Medicaid Managed Care CMS-2390-P Andrew Slavitt CMS8/4/2015 ABN Upgrade Within Same HCPCS Evelyn Blaemire/Arrah Tabe-Bedward CMS8/31/2015 LCD Revisions to Lower Limb Prosthetics Coverage Dr. Stacy Brennan DME MACs

8/31/2015LCD Revisions to External Infusion Pump Coverage Inotropic Dr. Stacy Brennan DME MACs

8/31/2015Proposed Rule CMS–1633-P: Hospital Outpatient Prospective Payment System Andrew Slavitt CMS

9/8/2015 Proposed Rule CMS–1631-P: Physician Fee Schedule Andrew Slavitt CMS9/21/2015 LCD Revisions to Surgical Dressings Dr. Stacy Brennan DME MACs

AAHomecare Regulatory Focus 2015

• Timely filing limit exemption where initial claim in audit status

• RAC oversight with new dedicated contractor

• Clarification on filing oxygen claim for denial when patient does not qualify

• CMN/DIF requirements removed

• OMHA appeals backlog recommendations and follow-up

• OIG competitive bidding report on access to care for beneficiaries

• EHR limitations and Medicare DMEPOS requirements

• ICD10 implementation challenges

Final Rule CB Pricing Expansion Regulatory Efforts

• Comments on ANPRM submitted 3/28/14

• CMS meeting Laurence Wilson/Joel Kaiser 6/4/14

• Comments proposed rule submitted 9/3/14

• CMS meeting Laurence Wilson/Joel Kaiser 10/7/14

• CMS released final rule 10/31/14

• CMS meeting Sean Cavanaugh 11/6/14

• Multiple strategy meetings with industry stakeholders and communication with CMS on clarifications on the final rule

VENTILATOR CODING CHANGES EFFECTIVE JANUARY 1, 2016

Exxx1 Home ventilator, any type, used with invasive interface (e.g., tracheostomy tube)

Exxx2 Home ventilator, any type, used with non-invasive interface (e.g,. mask, chest shell)

Codes to be discontinued effective December 31, 2015: E0450 E0460 E0461 E0463 E0464

The Medicare fee schedule amounts for code E0450 will be used to establish the fee schedule amounts for both new

Comments submitted: Pricing concernsAuthority to make the pricing change Pricing based on obsolete equipment Lack of appropriate notice and comment requirements 

CMS Proposes HCPCS Changes for Miscellaneous DME

CMS is proposed to revise the coding used to describe miscellaneous durable medical equipment (DME) E1399.

Likewise, HCPCS code K0108 describes a “wheelchair component or accessory, not otherwise specified” and is currently being used to bill for inexpensive DME, other covered DME, and replacement parts of wheelchairs. To promote more accurate payment of Medicare DME claims

HCPC # UNITS ALLOWED $ PAID $

E1399 74,809 $4,720,843.18 $3,665,892.50

K0108 153,571 $21,510,709.52 $16,725,059.51

AAH Comments Submitted July 9, 2015

AAH Comments:

• Did not give the public sufficient notice of the Agency’s plan to adopt new codes and assign new payment amounts.

• Proposes to create a new HCPCS coding logic that radically departs from the one the Agency has used over the last 25 years.

• Uses a payment methodology that does not follow the structure Congress established for the DME fee schedules under the Social Security Act (SSA).

• Trying to effect payment adjustments by way of coding determinations. • Will result in gross under or overpayment.

OCTOBER 2015 – CMS ANNOUNCED THEY WILL NOT BE IMPLEMENTING THESE CHANGES

Questions

QUESTIONS?

About

IntroductionSTATE LEADER POWER PANEL• Doug Coleman, Colorado Association

of Medical Equipment Services (CAMES)

• Karyn Estrella, Home Medical Equipment and Services Association of New England (HOMES)

• Rose Schafhauser, Midwest Association for Medical Equipment Services (MAMES)

• Laura Williard – ATHOMES, NCAMES & GAMES

• Kam Yuricich, Ohio Association of Medical Equipment Services (OAMES)

• Moderated by: Ashley Plauché, AAHomecare

Shelly Prial

Remembering Van