July 3, 2023
On Friday June 30, 2023, CMS released proposed updates to the Medicare Home Health Prospective Payment System for CY 2024. The proposed home health rule does not address home infusion therapy (HIT) services other than to describe the potential interaction with the new Home IVIG Items and Service benefit, which replaces the IVIG demonstration starting on January 1, 2024.
As NHIA expected, the permanent Home IVIG Items and Service benefit will mimic the demonstration. The description of the long-standing IVIG demonstration code, Q2052, will be modified and it will continue to be used for the permanent benefit. The payment allowable calculation will continue to be based on the LUPA rate. CMS is proposing a rate 2.7% higher than the 2023 demonstration rate, $408.23*1.027= $419.25. As in the demonstration, Q2052 must be billed to the DME MAC by same entity providing the immunoglobulin drug. The DME MACs will incorporate the home IVIG items and services payment into the IVIg LCD and related Policy Article, which should facilitate a smooth transition.
The proposed home health rule also includes DMEPOS policy proposals regarding the competitive bidding program, refills, and provider/supplier enrollment requirements.
NHIA is disappointed that CMS seems satisfied with the lack of access and utilization to HIT services and has once again neglected to take steps to improve the benefit. Home infusion has great potential to lower Medicare spending while improving the quality of life for beneficiaries with disabilities, those with transportation challenges, and lack of infusion access in their rural communities. For this reason, the association supports the bipartisan, bicameral Preserving Patient Access to Home Infusion Act, which would greatly improve home infusion access for these beneficiaries.
NHIA will submit comments, which are due August 29.
NHIA is accepting applications for members of the association’s Board of Directors. Board members serve 3-year terms as representatives for their NHIA member organization. Seats are only open to provider members and are assigned at the organization level.
The National Home Infusion Association (NHIA) expressed deep concern today regarding the recently proposed government funding bill, which includes major changes to the qualifying criteria for drugs under Medicare’s home infusion benefit but fails to address the underlying flaws that have plagued the program. Without fixing the structure of the benefit, Medicare beneficiaries in need of home infusions for treatment of a variety of medical conditions, including rare diseases, are unlikely to gain access to home-based care.
An independent analysis by Magnolia Market Access estimates that changes proposed by NHIA to the Preserving Patient Access to Home Infusion Act to expand Medicare Part B home infusion therapy services coverage to anti-infectives, and bundle payments for disposable supplies with the services payment would generate significant savings for Medicare.
