Georgia Association of Medical Equipment Suppliers
NEWS & NOTES


May 17 | 2018

In this issue:

  1. New Silver Member!
  2. GAMES meets with Medicaid
  3. Closer Look at the IFR
  4. Jurisdiction C Council
  5. Rural Health Open Door Forum
  6. Healthcare in the News
  7. Tell Your Story in DC!
  8. Defend CRT!
  9. Save these dates!

GAMES Platinum Members!









GAMES Associate Members
Support the associate members who support GAMES. If your vendors aren't on the list, ask them why!


Platinum


Airgas Healthcare
Christa Forrester
Mark Bradshaw



Drive DeVilbiss Healthcare
Joe Gessner
Steve Wakser




Philips Respironics
Susan Yenney


ResMed 
Jamie Griffis


VGM Group
Gil McCall
Pat Aydelott


Gold

BREAS 
Todd Tyson

Brightree
Melinda Mahoney

CAIRE

Lanier Hogan

Fisher & Paykel
Gregg Stahl

GCE Healthcare
John Lewis

Mediware
Michelle Caldwell

O2 Concepts NEW Member!
Ed Marlowe

The Compliance Team, Inc.
Jack Haire
Sandra Canally

The MED Group
Ted Metcalf

Silver

ACHC
Randy Hughes

Allegiance Group

Bruce Gehring

Cardinal Health NEW Member!
Brooks Bryant

Compass Health
Jim Mahon

Integrated Medical Systems (IMS)
Bo Lanier

McKesson Medical Surgical
Chip Wooten

Medical Specialties Distributors
Pat Burke

Medical Supplies Depot
Charles Simpson

Merits Health Products
NEW Member!
Elizabeth McKinley

Pride Mobility Products
John Storie

Quality Medical Inc.
Jim Worrell


Bronze

Medsolve Health Systems
Shane Morrison

Medtrade
Keving Gaffney

Pharmacists Mutual Insurance 
Hutton Madden



Welcome New Silver Member!

Cardinal Health provides clinically-proven medical products and pharmaceuticals and cost-effective solutions that enhance supply chain efficiency from hospital to home. Cardinal Health connects patients, providers, payers, pharmacists and manufacturers for integrated care coordination and better patient management.

CLICK HERE to tell Brooks Bryant "Welcome to GAMES!"


GAMES Committee Meets with Medicaid

On Wednesday, May 9, 2018, members of the GAMES Medicaid and State Issues Committee sat down with Peter D’Alba, Director of Pharmacy, DCH and Martha Moore, DME Program Specialist, DCH.

Enteral Nutrition

The GAMES Medicaid and State Issues Committee requested GA Medicaid consider covering formula for patients over 21. Mr. D’Alba indicated this was not very likely as it has been reviewed before and the impact to the State budget was too significant for Medicaid to consider.

 

As there is no clear path via the current Medicaid budget to accomplish this, GAMES would need to secure a lobbyist, collect detailed and accurate data that supports cost savings for the State by reduced re-admissions due to malnutrition or other issues caused by lack of access to specialized medical nutrition, and present a case for coverage through the State Legislature.

 

The second part of this discussion was the continued coverage of enteral supplies and accessories, such as feeding bags and feeding tubes, for patients over 21. Mr. D’Alba stated that the State never intended for these supplies to be covered over the age of 21. The fact that these supplies had been allowed to be covered for some time was an oversight. When this oversight  was discovered a few weeks ago, coverage was discontinued for supplies over the age of 21. Due to the negative impact on patients and providers, Medicaid began covering the supplies again but it will only be temporary. Medicaid wanted to give patients and providers enough notice to be prepared for this change. A policy amendment to clarify is forthcoming and Medicaid will stop covering all enteral supplies for patients over 21 with the July 1st or September 1st policy release. D’Alba specifically asked that we not notify our customers of this change until there is a confirmed date of implementation. He will let us know as soon as possible so we can then inform our patients.

 

Claims & Prior Authorizations

The second topic discussed was the recent development where claims and auths are being denied because the HCPC codes are not included on the CMN’s signed by the physician. D’Alba indicated that their policy does state the HCPC is required but acknowledged a contradiction where the policy allowed providers to use the State provided CMN’s that did not include the billing codes. He apologized and said that they would cover these pending claims and auths that were denied for this reason, but that from this point forward providers would be required to include HCOC codes on all CMN’s. This will also be clarified in the next policy update. Providers with any remaining claims or auths for dates of service prior to our meeting (May 9th) should contact Martha Moore, DME Program Specialist at DCH for assistance.

A Closer Look at the Rural Relief IFR

From AAHomecare, May 16, 2018

Last week’s release of the long-awaited Interim Final Rule on rural relief was met with a measure of disappointment for many in the home medical equipment community on account of the shorter-than-expected period of relief, the lack of relief for non-CBA suppliers not located in rural areas, and the lack of clarity on reimbursement rates beyond the end of 2018.  However, the IFR does provide needed relief for rural suppliers and other provisions that could positively impact future reimbursement policy.  Here’s a closer look at what’s in the IFR and how it sets the stage for our next steps.
 
Seven Months of Relief for Rural Suppliers; Action Also Mitigates O2 "Double Dip” Cuts Over that Term 
  • Relief for suppliers in rural areas and non-contiguous states (i.e., Alaska, Hawaii, and US Territories) will have new rates that will consist of 50% 2018 rural fee schedule and 50% 2015 fee schedule beginning June 1, 2018 until December 31, 2018.
  • Due to this adjustment, the effects of the stationary oxygen "double dip” cuts for rural and non-contiguous areas are mitigated during the 7-month relief period. 
  • Continues to extend the exclusion of CRT accessories from competitive bidding.
CMS Acknowledges HME Stakeholder Concerns
  • Language in the IFR acknowledges that claims data doesn’t capture all the challenges experienced by beneficiaries and suppliers.  The IFR also acknowledges that there’s been a decrease in number of supplier locations and that they are continuing to decline, noting a 7% decrease in number of suppliers from 2015 to 2016.  Here are some of the most salient passages from the IFR:
  • Given the rapid changes in health care delivery that may disproportionately impact rural and more isolated geographic areas, we are concerned that the continued decline of the fees and the number of suppliers in such areas may exacerbate the already emergent access concerns faced by beneficiaries.
  • Our monitoring data, by its very nature, would not alert us to the present and imminent threats to beneficiary access that stakeholders have raised in recent months. If CMS continues to pay the fully adjusted payment rates in rural and non-contiguous areas, it could further jeopardize the infrastructure of suppliers that beneficiaries rely on for access to necessary items and services in remote areas of the country.
  • Also, as noted earlier, our systematic claims monitoring only looks backward in time and may not detect rapidly emerging trends, particularly in isolated or rural areas. We also referenced the GAO’s acknowledgement that there are challenges associated with monitoring the CBP.
  • We recognize that reduced access to DME may put beneficiaries at risk of poor health outcomes or increase the length of hospital stays.
  • Given the strong stakeholder concern about the continued viability of many DMEPOS suppliers, coupled with the Cures Act mandate to consider additional information material to setting fee schedule adjustments, it would be unwise to continue with the fully adjusted fee schedule rates in the vulnerable rural and non-contiguous areas for 7 months. Any adverse impacts on beneficiary health outcomes, or on small businesses exiting the market, could be irreversible. 
CMS has been very resistant to acknowledge and address these issues in recent years, so the volume and change in tone in these statements is very encouraging. 
 
Where the IFR Falls Short
As we noted earlier, the IFR falls short in these critical areas:
  • No relief for non-CBA suppliers in non-rural areas. 
  • The relief covers just a 7-month period and does not provide guidance for 2019 and beyond.
  • Does not permanently address the O2 "double dip” cuts.
Going Forward
While we will continue to engage CMS and the Administration on long-term, sustainable Medicare reimbursement policy for all suppliers, including those in bidding areas, rural suppliers, and other non-bid suppliers, it’s clear the only realistic near-term avenue for more substantial relief for both rural and other non-bid area suppliers runs through Capitol Hill. 
 
Approximately 150 HME stakeholders will be on Capitol Hill next week to build support for H.R. 4229 as part of AAHomecare’s Washington Legislative Conference.  Congressional outreach to CMS and OMB were critical factors in getting the Administration to finish work on the IFR, and these two months will be critical to efforts to keep the House and Senate engaged on both rural and non-bid reimbursement issues, as well as on reforms for the next round of the bidding program. 
 
We look forward to continuing to work with the persistent and passionate leaders from across our industry to deliver more substantial and long-term relief for all HME suppliers. 


Jurisdiction C Council

GAMES is a member of the Jurisdiction C Council, a coalition of suppliers for all states handled by CGS. Its purpose is to meet quarterly with CGS, the Jurisdiction C DME MAC, to suggest, review and resolve problems in operations.

GAMES is represented on the Council by Trish Clayton of Barnes Healthcare Services.

Jurisdiction C Council/CGS Meeting May 9, 2018

From Provider Outreach:
  • Two new tools have been added to the website. 1. PAP Tool 2. Lipid Calculator 
  • June 5th-Ask the contractor-Diabetic Shoes
  • June 12th-Mega Workshop-Nashville
  • MBI look up tool coming in July
  • No major changes are planned for CGS website however, they are aware the search function is not working properly and are working to correct.
  • QMB reprocessing for October-December suppressed patient responsibility errors are currently being reprocessed.  This is expected to take 15 weeks to complete. They are currently processing 30,000 claims per weekend. The issues providers are going to have is that most Medicaid plans do not accept adjusted claims. This will be a manual process for providers.
  • PECO’s claims edits for retired/deceased physicians that are past the timely filing should be submitted to written re-openings.
Medical Policy/Noteworthy Updates:
Billing instructions for Oxygen CMN Questions 5 has been revised. Providers should educate physicians completing the oxygen CMN to follow the instructions included on page 2 of the CMN. Refer to the article dated April 26th.

Providers have been receiving denials for home assessment for manual wheelchairs when they are documented as done by interview rather than in-person. These denials say that a physical in-home assessment with measurements is required. Frequently these chairs are delivered to a facility to facilitate discharge, and the provider is not physically going to the beneficiary’s home.

The LCD states the home assessment may be done directly or indirectly.

The beneficiary’s home must provide adequate access between rooms, maneuvering space and surfaces for use of the manual wheelchair (Criterion C). We asked for clarification regarding these denials and explanation of directly and indirectly. The response we received was per the policy article for manual wheelchair the home assessment may be done directly by visiting the beneficiary’s home or indirectly based upon information provided by the beneficiary or their designee. The policy article further states that when the home assessment is based upon indirectly obtained information the supplier must, at the time of delivery, verify that the item delivered meets the requirement specified in Criterion C. The home assessment must include documentation addressing the physical layout of the home, surfaces to be traversed and any obstacles.

The Medicare rule includes provisions to allow DMEPOS items to be delivered to the beneficiary within 2 days prior to discharge from an inpatient facility for the purpose of training and fitting. This provision does not in any way negate the supplier’s obligation to conduct an in-person home assessment to meet all the requirements related to criterion C.  The supplier is obligated to ensure that the wheelchair provided will provide adequate access between rooms, maneuvering spaces and surfaces to allow the beneficiary to perform or participate in  mobility-related activities of daily living (MRADL’s).

The council expressed concerns that this rule is requiring the supplier to make two deliveries when a patient is being discharged from facilities and requires the wheelchair to be delivered to the facility. This is being taken into consideration however as it stands now suppliers must do a physical home assessment.

CLICK HERE to submit questions or comments for the next Jurisdiction C Council Meeting.
 
GAMES is allowed 2 seats on the Council. One seat is currently open. Please CLICK HERE if you are interested in being considered for this open seat.

CMS Announces Rural Health Open Door Forum

Thursday, May 17, 2018
2:00 pm-3:00 pm  

Topics include:
1.         Rural Health Strategy
2.         Durable Medical Equipment Fee Schedule Adjustments in Rural Areas
3.         Medicare’s FY 2019 Payment Rules 

To participate by phone:Dial: 1-800-837-1935 & Reference Conference ID: 33234668

Learn more at:

https://www.cms.gov/Outreach-and-Education/Outreach/OpenDoorForums/ODF_RuralHealth.html

Healthcare in the News

These stories are straight from the headlines in Georgia this week! 

New reports says Medicaid expansion would cover 473,000 more Georgians
A new report estimates that a full Medicaid expansion in Georgia would provide health insurance to 473,000 more residents in 2019. 

A political race that has big implications for health care
Georgia's high rate of people without health insurance.

Bill limits Medicaid access to estates
Advocates are celebrating the signing of a bill they say will ease the financial burden on the families of deceased Medicaid recipients.

Trump's prescription to reduce prices takes small steps
President Donald Trump's long-promised plan to bring down drug prices would mostly spare the pharmaceutical industry he previously accused of "getting away with murder."

Healthcare reforms still on the table
Legislation that would have created a state healthcare innovation center is dead, vetoed by Gov. Nathan Deal - but some initiatives that would have fed the center's efforts at stabilizing costs and improving access are moving ahead.


We Need You in DC!

Directly engaging Members of Congress and their staff is the most effective way to build relationships and secure their active support for HME public policy priorities. The AAHomecare Washington Legislative Conference is the best opportunity to advocate relief for rural/non-bid suppliers and enlist Congressional support for important reforms for the next round of the bidding program. With hundreds from the HME community across the U.S. joining together to speak with one voice, we can make an impact on Capitol Hill.   

Join with other Georgia DME providers as we advocate for better public policy and sustainable reimbursement rates for HME! Make plans to attend the Washington Legislative Conference next month in DC! 

CLICK HERE for registration information.


Defend CRT: Need Signatures on this House Letter to CMS

From NCART May 16, 2018

As we told you last week, Representatives Bob Latta (R-OH) and Bill Johnson (R-OH) are circulating a House of Representatives letter that will be sent to CMS Administrator Verma to protect access to Complex Rehab Technology (CRT). The letter formally informs CMS that Congress did not intend for DME Competitive Bid payment rates to be applied to CRT items as part of the 21stCentury Cures Act legislation.

Our task is to strengthen their message by getting additional Representatives to sign-on to the letter. We have until noon next Friday, May 25th to get those signatures and need your help.

Here's what you can do
: Click here to send an email to your Representative asking them to follow the instructions included to add their signature and help protect access to CRT. All you need to do is enter your information and click send.
A copy of the instruction letter and the text of the letter to CMS can be found here.
Your prompt attention is appreciated. Please let us know when you secure your Member's signature so we can continue to monitor progress!

Regards,

Donald E. Clayback
Executive Director, NCART
Office 716-839-9728
dclayback@ncart.us

Save These Dates!

AAHomecare Washington Legislative Conference
May 23-24, 2018
Washington, DC

VGM Heartland Conference
June 19 - 21, 2018
Waterloo, IA

GAMES 2018 Annual Meeting
September 9-11, 2018
The DeSoto 
Savannah, GA