September 30, 2025
NHIA released a new white paper, “Trends in Home Enteral Nutrition—The Impacts of Competitive Bidding on Access and Quality,” which documents the declining payment structure for clinical services needed to support patients on home enteral nutrition. An estimated 220,000 individuals in the United States rely on home enteral nutrition (HEN), which demands clinical coordination, specialized equipment, disease-specific nutrition formulas, and a multidisciplinary team to ensure safety, efficacy, and quality of life.
But, the Medicare Competitive Bidding program, introduced in 2011, changed reimbursement, resulting in a model that lacks payment for the post-acute clinical services necessary to support positive patient outcomes on HEN. The program has gone through several bidding and implementation phases, as well as pauses. It is now in a temporary “gap period” awaiting a formal public notice and comment rulemaking process to make changes to the program.
Although government reports indicate that Competitive Bidding has not negatively impacted access to HEN, NHIA reviewed publicly available Medicare DME utilization data and found the number of suppliers billing for HEN kits has decreased by 31% over the past decade, while the number of Medicare beneficiaries accessing HEN has declined by 27%. The market conditions created by Competitive Bidding may influence other payor policies as well. According to reports, 1 in 4 HEN providers are considering or planning to discontinue providing HEN formulas or supplies due to cost pressures.
NHIA believes that certain reforms would improve outcomes and the quality of life in HEN patients, while lowering the total cost of care. CMS should perform a comprehensive study of HEN services, patient access, and impacts on overall costs of care; newly developed supplier standards should reflect clinical support expectations and standardized outcomes; and a new service code should be added for clinical activities such as performing nutritional assessments, monitoring nutritional status, making formula changes, troubleshooting problems, and providing nutrition education and support.
NHIA submitted comments to CMS on a new proposed rule on interoperability and prior authorization for drugs. While NHIA is mostly supportive of standardizing prior authorization (PA) processes for Medicare-covered drugs, it wants CMS to know that home infusion may not fit neatly into processes designed for medical and pharmacy benefits.
NHIA strongly opposes CMS’s proposed HCPCS coding and billing unit changes for immune globulin products, arguing that the changes would create significant administrative, operational, reimbursement, and patient care challenges without providing meaningful clinical or financial benefit.
The National Home Infusion Association (NHIA) has received clarification from CMS regarding enrollment options for home infusion pharmacies under the current nationwide DMEPOS enrollment moratorium.
