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.