Take your shot

These were some of the reactions of industry stakeholders to the news of CMS’s proposed national coverage determination for home oxygen therapy:

“Groundbreaking.”

“We haven’t seen something this major happen in a long time.”

“This obliterates everything that we’ve held to be immovable ground for oxygen coverage.” 

If you’re like me, when you first saw the news on that Friday before a long holiday weekend (classic CMS move, by the way), you were underwhelmed. Cluster headaches? They’re not that common, are they? The agency is revising the NCD for cluster headaches? 

Upon closer examination, however, the proposed NCD also seeks to, among other things, expand coverage for acute conditions and remove the CMN requirement. 

Groundbreaking, major, obliterating. 

So how did we get here? 

VGM’s Ronda Buhrmester told me that when CMS opened up the NCD in September 2020 to address cluster headaches, stakeholders were encouraged to submit comments on home oxygen therapy beyond that condition. 

“Because it hadn’t been opened up since 1993, this was our opportunity to make recommendations,” said Buhrmester, senior director of payer relations and reimbursement for VGM & Associates.  

And make recommendations they did. 

“We developed a workgroup with various suppliers and AAHomecare, and we came up with our big wish list,” Buhrmester said. 

In an email bulletin following the news, AAHomecare said the majority of its recommendations are included in the proposed NCD.  

It didn’t hurt, of course, that CMS opened up the NCD during a pandemic that significantly increased the number of people needing oxygen and exposed issues with the current NCD.  

“The biggest thing that happened was all the change,” said Kim Brummett, vice president of regulatory affairs for AAHomecare. “It wasn’t so much our compelling comments, as it was COVID-19 that really changed the world.” 

Whichever way you look at it, stakeholders took their shot – and it’s paying off.