Advocacy for Homecare Providers and HME/DME …



2019 Regulatory Council GoalsMonitor, evaluate and respond to Competitive Bidding 2019 reforms. Ensure industry is educated and prepared for bidding.Quarter 1 Update: CMS OUTREACH EFFORTSBelow are efforts that have been made on the regulatory front since the announcement of the new bidding structure:12/16/18 Submitted letter to CMS to not include ventilators to the competitive bidding program. 1/7/19 Initial meeting with CMS on concerns with final rule and product category groupings.1/31/19 Submitted recommendations to CMS on product category grouping under lead item pricing2/7/19 Submitted recommendations to CMS on supplier capacity. 3/1/19 Submitted recommendations on bona fide bid analysis. Next: AAHomecare will meet with CMS to discuss submitted recommendations in-person.INDUSTRY EDUCATIONAL EFFORTSWorking with leading industry trade organizations to ensure the DMEPOS industry is fully prepared and educated about the new bidding process. An educational website which will be a one-stop shop about the new round of competitive bidding. The website has been launched and new content and tools will be available as new information is announced by CMS. EDUCATION SESSIONS AND WEBINARSDeveloping schedule and plan for these to be conducted.Quarter 2 Update:CMS OUTREACH EFFORTS4/9/19 Meeting CMS on written comment submission for capacity, bona fide bid.INDUSTRY EDUCATIONAL EFFORTS4/11/19 Meeting with Philips on CB reach out efforts Wellsky CB discussion Industry consultants group call on CB education and website5/9/19 Wellsky additional discussion on CB educational efforts6/3/19 QS1 discussion on CB 3,283 unique visitors month to date 12,400 unique visitors year to date 6,902 (62.1%) direct visits2,701 (24.3%) referral visits1,001 e-mail subscribers5,277 calculator downloads since 4/29/2019EDUCATION SESSIONS AND WEBINARS5/20/19 Webinar over 400 attending6/5/19 Summit in Nashville 130 attendingEvaluate, review and respond to all issues advanced notices of proposed rules, proposed rules, LCD revisions, MUE adjustments within the timeframe specified; including MedPAC recommendations to expand competitive bidding and make additional changes to DMEPOS requirements. Follow-up with CMS and other entities on comments submitted as appropriate.Quarter 1 Update:DateLetter/CommentTo Whom1/11/2019Comments on CMS-2408-P Medicaid Managed Care Proposed RuleSeema Verma1/17/2019Recommendations on CB 2021 Product Categories and Lead ItemsLaurence Wilson2/7/2019Recommendations on CB 2021 Supplier CapacityLaurence Wilson2/11/2019HHS-OCR-0945-AAOO, “Request for Information on Modifying HIPAA RulesAlex Azar3/1/2019Recommendations on CB 2021 Bona Fide Bid AnalysisLaurence WilsonQuarter 2 Update:DateLetterTo Whom5/14/2019PDAC Website RecommendationsPDACResearch CMS directions to QIC Contractor as part of demonstration project and work with CMS and the DME MACs to seek changes to CMS guidance to allow the same flexibility in audit evaluation for DME MACs, SMRC and RAC. Quarter 1 Update:AAH has reached out to CMS, C2C (QIC Contractor), DME MAC to gather information on what all of the flexibilities are to review and determine which items we would like to address and next steps.Quarter 2 Update”The QIC telephone demonstration does not end until 12/2020. AAH has discussed with Maria Ramirez at CMS what specific items are allowed to be adjusted as part of the appeal process. AAH has been informed that CMS intends to request an extension of the demonstration as it gets closer to the termination date. AAH continues to work with appeals and program integrity to incorporate flexibility in documentation requirements.Monitor TPE issues and work with DME MACs and CMS to determine mechanisms to adjust the requirements to allow flexibility and consistency via direction from CMS in the form of TDLs and CRs. (i.e. proof of delivery and refill documentation)Quarter 1 Update:The regulatory council has created a TPE document with concerns and issues that has been shared with the DME MACs and CMS. A conference call was help in March with CMS to review in more detail the TPE document. 2 changes have been made to assist with the TPE process; the pilot pre-TPE process where the supplier receives a 10 claim audit and if successfully passes all 10 is removed from the TPE process and exempt for one year for the HCPCS code, direction issued to MACs to pull round 2 and 3 audit samples based on date of service and not submission date which allows for education and changes of operational processes before next step audits.Quarter 2 Update:The regulatory council has created a subgroup to focus on TPE issues. Our issues and questions document version 3 were created 06/2019 and shared with CMS. AAH will assist with a TPE panel discussion at Medtrade 2019 in October. AAH held 2 conference calls with CMS on 5/9/19 and 6/3/19.AAH created a workgroup to focus on TPE issues specific to oxygen including chronic stable state versus hospital discharge, acute versus chronic condition and other treatments tried and ruled out. AAH held an initial call with CMS and provided 4 examples of denied TPE audits for CMS to review. Workgroup is seeking additional examples of denied TPE audits, 5 per jurisdiction to approach CMS and continue discussions. ................
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