Advocacy > Nutrition Support Advocacy

NHIA Advocacy

Nutrition Support (Home Parenteral & Enteral Therapy)

Why this matters now

Home nutrition support keeps people out of the hospital, improves quality of life, and lowers total health care costs—but access is at risk because reimbursement has not kept pace with real-world costs. NHIA’s latest analysis shows this value is at risk as real-world costs (ingredients, labor, compliance) have surged while payments lag, eroding provider participation. Aligning payment with current costs and modernizing coding and contracting can protect access and reduce total cost of care by preventing complications, emergency visits, and unplanned admissions.

Home Parenteral nutrition (HPN)
Roughly 32,000 Americans depend on HPN each year. Since 2016, the compounded average cost to prepare a bag of HPN rose 75.4% through 2024, while average reimbursement for HPN services declined from 2022–2024—pushing pharmacies out of the service line. Drivers include persistent ingredient shortages (17 of 24 PN components on shortage lists in the past two years), policy changes that spike prices, rising labor and compliance costs, and a bundled payment model that hides drug inflation inside a fixed per-diem.

See the chart on page 2 of Ensuring Sustainable Access to Home Parenteral Nutrition: The Cost Crisis and Path Forward showing the compounded increase in PN bag cost reaching 75.4% by 2024.

Home Enteral nutrition (HEN)
HEN is a lifeline for an estimated ~220,000 people in the U.S., yet post-acute clinical services to support HEN are largely unreimbursed. Medicare’s DME Competitive Bidding Program has driven down reimbursement for pumps, formula, and supplies; across 2014–2023, Medicare HEN kit suppliers fell ~31% and beneficiaries using HEN fell ~27%, despite an aging population and rising Medicare enrollment. About half of HEN patients require pump-assisted feeds, underscoring the need for service and equipment support.

Priority Issues & Recommendations

1.

HPN payment structure masks cost shocks and underpays complex care.
Standard HPN components are locked inside a fixed per-diem, so ingredient inflation and shortages drive costs up while payment rates stay flat—unlike other drugs where payment adjusts to benchmarks (Average Wholesale Price, Average Sales Price). Wage growth and USP <797> updates also require sustained investments in facilities, training, and QA.

Recommendations: Update contracted rates to reflect ingredient, labor, and compliance pressures and allow separate billing for PN components (via NDC/HCPCS—e.g., B-codes for grams of protein/lipids).

2.

HPN provider capacity is shrinking due to the costs–payment gap.
Compounded HPN bag costs rose 75.4% (2016–2024) while average monthly payments decreased from 2022–2024, contributing to declining claims-submitting pharmacies and access challenges. In addition to the expense associated with compounding HPN, pharmacies provide advanced clinical support through a multi-disciplinary team to ensure safe and effective therapy. Services tend to be more intense when patients first transition home, amplifying the up-front risk of serving patients under a per-day payment model.

Recommendations: Ensure adequate, in-network HPN providers (same-day nursing/deliveries) and pilot value-based HPN models that reward outcomes such as reduced re-hospitalization in the first 30 days, lower catheter infections, and lower total cost of care. Consider legislative incentives for PN cleanrooms, equipment, and staff training. States should also examine whether sufficient access exists for HPN among the Medicaid population and look to early state action such as Colorado SB25-084 to improve access for Medicaid patients.

3.

Medicare’s Competitive Bidding program depressed allowables for HEN, leaving clinical support services unfunded. As a result, few providers offer HEN.
Since 2014, Medicare HEN beneficiaries and kit suppliers have both declined, and average allowables were lower in 2023 than a decade prior—straining access and clinical services.

Recommendations: Recognize and fund the clinical nutrition support services (assessment, education, monitoring, troubleshooting) required to keep patients safe at home.

Modernize HEN payment & oversight. Direct CMS to study HEN access/quality/costs; add service codes for clinical care; and consider removing EN from competitive bidding—including demos designed to reduce total care costs while preserving access.

Featured White Papers (NHIA)

What’s inside: Eight-year cost trend analysis (2016–2024) showing 75.4% compounded rise in PN bag costs; reimbursement declines 2022–2024; effects of shortages, UDI, USP <797>, and staffing; time burden (pharmacists average 42 minutes/day per HPN patient).

Key steps: Update rates; enable separate billing for PN components; ensure adequate networks; pilot value-based PN; consider legislative support; note Colorado’s Medicaid steps.

What’s inside: HEN overview and population size (~220,000); modality mix (~55% pump-feeds); Medicare policy timeline; analysis showing 31% fewer suppliers and 27% fewer beneficiaries since 2014; call for modernized service payments.

Key steps: CMS study of HEN services; develop supplier quality standards; add service codes or episodic payments for clinical care; remove EN from CBP.

What’s inside: Early evidence of pandemic-era shocks—50.12% cumulative PN bag cost increase over 2016–2021 and 9.88% average increase across 223 disposable SKUs in 2021; explains how PN “standard ingredients” bundled in per-diems obscure inflation.

Key steps: Adjust per-diems to actual costs; allow separate billing for non-standard PN components (e.g., lipids, specialty amino acids).

Commercial payor advocacy news

NHIA Releases 2024 Commercial Payor Recommendations

The National Home Infusion Association (NHIA) has developed recommendations for commercial, Medicaid, and Medicare Advantage payors to improve patient outcomes and experience, reduce administrative burden, and improve timely access to home infusion services.

Read More »

NHIA Home & Alternate Infusion Payor Summit

NHIA's 2023 Payor Summit was held August 23, 2023 in Dallas, TX. The summit, exclusive to leaders from commercial payors, provided an interactive forum to learn about current trends in home and alternate site infusion to help improve how these services support health plans and their beneficiaries.

The meeting is mostly beneficial to commercial payors with responsibilities for benefit structure, network decisions, population health, value-based programing, specialty infusion policy and medical directors.