American Association for Homecare
About ABOUT AAHOMECARE Introduction • National voice for home medical equipment providers and manufacturers in Washington. • AAHomecare fights for fair regulations and sustainable reimbursement rates from government payers. • Member-driven association: guided by our council structure and board of directors. • Unifying voice for our industry though strong partnerships with major stakeholder organizations and state/regional associations. • Continuing to grow our membership. YOUR ASSOCIATION, YOUR ADVOCATE, YOUR VOICE
AAHomecare Multi-Pronged Approach AAHomecare is employing a wide range of resources and working on multiple fronts to achieve goals: • Continued engagement with CMS, HHS & OMB Including Medicare, Medicare Part C, Medicaid, Duals Oversight Offices • Maintaining interest on Capitol Hill • Outside counsel & lobbying support • HME community grassroots engagement
Going Forward • Work towards relief for relief on rural and non rural reimbursement rates – impacts broad range of payers. • Advocate for fair, common-sense regulations that help us put patients over paperwork. • Work with state and regional association leaders on Medicaid rates and other managed care payers • Continue to grow AAHomecare so we can bring more resources to fight for HME interests in Washington and at the state level, and continue to build the advocacy capacity of our industry.
Bey eyond M d Medicare e Reimbursement L Landscap ape • Managed Care Market hiring consultants to save money and lower employer health care expenses in competitive market place • Most Consultants recommending large decreases in DME and Supply Rates • BCBS Association has a group focusing on cost savings and value based networks exclusively • BCBS WNY PAP Pay for Performance Pilot • Carecentrix Collaboration
Payer Relations Resources • WWW.AAHomecare.org • https://www.aahomecare.org/advocacy/payer-relations-resources • Cures Legislation for Medicare Advantage/Medicare-Based Plans Legal Language regarding plans pegging rates to Medicare and their obligations as rates change Contractual Language may trump • Medicare Regional Pricing Comparison Shows drastic rate decreases in Medicare Pricing Use Opportunity to discuss CB Program and what it has done to industry True Cost of HME Study-Executive Summary Dobson Davanzo, LLC Completed-Actuary Firm in DC Area Data and facts around unsustainable reimbursement based on Medicare rates • Sample Provider Letter to DOD on Cures Information provided citing legislation tying reimbursement to Medicare rates Use when rates change with Medicare and contractual renegotiations occur with contractors • Summary of Medicaid Cures Implementation Information for discussion with State Medicaid Programs Information for discussion with Medicaid MCO plans incorrectly linking rates to Medicare based on Cures Use with “Federal Match for DME Expenditures & Medicaid Payment Rates Analysis (January 2017)-Legal Opinion from B&F • New Supplier Tracking https://www.aahomecare.org/uploads/Document-Library/27dc166162dc8758a8a1abecb1531d7f.pdf Information on Suppliers and Locations out of Business by State
Impact o of Competitive B Bidding o on Medicare Benefic icia iary ry Acc Access to to D DME ME The survey was completed by • 428 patients, 358 case managers, and 266 suppliers. 52% of beneficiaries reported • problems. 77.6% of case managers • experienced difficulties with timeliness of discharge process due to HME access issues. 89% of case managers report • an inability to obtain DME in timely fashion. 62% of case managers say • patients are having medical complications, some of which result in readmission to the hospital.
Comparison of T Two I Independent S Studies ATS Survey Dobson Davanzo Survey # of Respondents 1,926 1,064 (428 beneficiaries) Survey Timeframe 54 days (9/1/16- 34 days (8/11/17-9/13/17) 10/24/16) Geographic Focus Nationwide Survey, Nationwide Survey, comprised of those in comprised of those in Competitive Bidding Areas (CBAs) and Competitive Bidding Areas outside CBAs. (CBAs) and outside CBAs. Process for Identifying Input from patient, Input from industry stakeholders, Content for Survey advocacy, professional, including former executives and advocacy and payor organizations personnel
Two S Studies R Respon onses • ATS Study-51% of respondents reported “problems” in accessing oxygen, DME, and services. • Dobson Davanzo Study-52.1% of beneficiaries reporting problems accessing DME and supplies. • Both studies point to approximately half of patients who require DME and supplies associated with oxygen therapy expressing or experiencing problems.
CURES Legislation • Will limit the federal contribution for DMEPOS for 244 select E, K, and A codes. List available from CMS or AAHomecare • States can still set their own payment rates to ensure access to care. • States do not have to do anything to be in compliance with this regulation. • States will have to complete annual reconciliation by 3/30/2019. Primary Fee For Service Claims Only No MCO No secondary claims Aggregate expenditure for HCPCS code listing only Include area patient lives or reconciliation will occur to lowest Medicare allowable in the state • Medicare Rates Unsustainable Due to Flawed Competitive Bidding Program
Medicaid Landscape-CURES • 75,179,773 Medicaid Enrollees Nationwide • 72.70% of Medicaid Beneficiaries are enrolled in Medicaid MCO • Cures impacting 20.5 million beneficiaries directly • Cures impacting 54.6 million beneficiaries indirectly through MCO plans following Medicaid rates
AAHomecare Cures Actions • Guidance requested early 2017 • In Person Meeting with CMS to update guidance to include option for Cures related HCPCS only and to provide HCPCS list- September 2017 • CMS Webinar 12-7-17-First guidance from CMS-Missing Information States Needed • State Medicaid Director Letter-12/27/17 with 12/31/17 deadline • Updated State Medicaid Director Letter-1-4-18 • Foley Hoag Engagement-CMS Pressure • Legislative Pressure from Congress • State Association Involvement • 23 State Medicaid Meetings • 6 Other States Involved with State Associations
State Responses on CURES • 11 States changing rates to Medicare • 6 States already at Medicare rates • 13 States Not Changing Rates and will complete reconciliation • 10 States Analyzing Decision • 1 State Accepted Proposal of limited codes
State Responses on CURES CURES Medicaid Implemenation Analysis States Already At Or Below Medicare Rates (6) DC – Mississippi – Nevada [will be reducing to 2018 rates] – Virginia – West Virginia - California States Changing Rates to Medicare (11) Vermont [all HCPCS] – Montana [ll HCPCS but CRT] – Washington [all HCPCS but CRT] – Colorado [CURES codes only] – Kentucky [Cures codes only] -Alabama [CURES codes only] – North Dakota [CURES codes only] – Connecticut [CURES codes only] – Maine [need information on which codes] – Massachusetts [need Information on which codes] - Tennessee [Cures codes directive to MCO plans] States Not Changing Rates (13) Florida – Georgia – Hawaii – Michigan – Minnesota – North Carolina – Ohio – Pennsylvania – South Carolina – Iowa – Texas – Indiana – Rhode Island States Currently Analyzing Fee Schedule and Data (10) Oregon – Illinois – Kansas – New York – Oklahoma – New Hampshire – Wisconsin – Nebraska – South Dakota - Alaska **Information based on meetings and/or discussions with state Medicaid plans or State Plan Amendments filed with CMS. Listing is subject to change as further analysis occurs. States not listed have not discussed their plans or filed State Plan Amendments. Updated July 9, 2018
AZ & NM Responsibility with CURES • MCO Plans are not included in legislation • Secondary Claims not included in legislation • Arizona 88.31% MCO • New Mexico-88.81% MCO • To date no SPA updates posted • Work with State Medicaid programs as necessary • Partner with MCO plans and SWMESA as necessary
Medicaid MCO Strategy • State associations relationships with state Medicaid programs even when population is mainly MCO • Collaborate with state associations and state Medicaid programs to evaluate RFP for new MCO states and existing as they are up for renewal • Some states have allowed for submission of regulations for review by state to be entered into RFP consistent medical policy consistent prior approval policy Medicaid rate floor Timeframes for switching plans
Engage S State Le Legislators to Better O Our Industry State Legislative Day on the Hill • Consistent Meetings/Relationship Building • Reach out for help with state Medicaid programs • Impact is on jobs in the state-commercial payer stance •
State Legislative Items-Not Just a Federal Fight Any Willing Provider • Medicaid Rates-Payment Floor • Medicaid Rates cannot follow competitive bidding • No Audits for Medical Necessity for Prior Approved Items • Consistent Medical Policy for State Medicaid Programs • Audit and Recoupment timeframes • Sole Source-Narrow Network Elimination or Approval • Opt in or Out of Sole Source Arrangements • MCO Ownership of own DME company • Proof Of Delivery Consistency •
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