CMS doubles down on vents

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Tuesday, November 20, 2018

WASHINGTON – Industry stakeholders were caught off-guard by a proposal in a recent final rule to include numerous types of ventilators in Medicare’s competitive bidding program.

CMS proposed but backed off from including vents in the program before—non-invasive vents for Round 1 2017—but this time, it has proposed including not only non-invasive but also invasive and new multi-function vents.

“We had no inkling they would expand the product categories at all, let alone to ventilators,” said Kim Brummett, vice president of regulatory affairs for AAHomecare. “It’s a risky thing to put in competitive bidding because you don’t know if patients will have access to these devices.”

CMS announced earlier this month that it was seeking comments on adding three new product categories to the bid program: ventilators, and off-the-shelf back and knee braces.

The possible addition of vents, particularly invasive vents, sets a dangerous precedent, say providers.

“We feel people are going to be in jeopardy,” said Bill Hart, director of clinical services for Auburn Hills, Mich.-based Advent Home Medical. “The invasive side is much more serious and the patients much more fragile.”

Providers already took a hit on reimbursement for vents, when CMS, in an attempt to rein in skyrocketing utilization rates, overhauled the product category and reduced reimbursement by about 33% in 2016.

If CMS truly wants to improve the product category, say providers, it needs to issue local coverage determinations, something the industry has requested and the agency has so far declined to do.

“With a true LCD, clear qualification criteria and usage requirements, we as an industry could better partner with CMS and other healthcare systems to drive superior outcomes, and save the overall system significant dollars,” said Eric Mongeau, vice president of sales and marketing for Norwood, Mass.-based Reliable Respiratory. “Those end points should be the ultimate determining factor when CMS considers whether or not to include these codes in the next round of competitive bidding.”

AAHomecare has formed a ventilator workgroup to develop comments on the proposal. The VGM Group has pulled together talking points for providers who plan to comment. Comments are due Dec. 3.

CMS has proposed adding the following codes to the next round of the program in 2021, after a two-year gap period: E0465, E0466 and E0467; L0450, L0455, L0457, L0467, L0469, L0621, L0623, L0625, L0628, L0641, L0642, L0643, L0648, L0649, L0650, L0651; and L1812, L1830, L1833, L1836, L1848, L1850, L1851, L1852.