The home health proposed rule drew powerful opinions during the public comment period from home health and hospice providers. It also elicited a strong reaction — positive and negative — from another corner of the home health world: durable medical equipment (DME) providers.
One provision in the proposed rule that pleased commenter Linda Langiotti, senior vice president of strategic channels for CCS, was the move to expand the 14-day window for contacting patients for supply refills to 30 days. CMS also indicated that the supplier’s documentation of an affirmative confirmation is enough to satisfy the refill. CCS is a key distributor of insulin pump and associated supplies, and a major provider of continuous glucose monitor (CGM) equipment and supplies.
“We applaud the government for doing all that,” Langiotti told McKnight’s Home Care Daily Pulse in an interview last week. “That’s really, really positive.”
But in her letter, Langiotti also urged CMS to change certain policies going forward. As an example, she urged CMS to relax rules regarding refill consents for certain beneficiary populations who do not see fluctuations in their device or supply quantity. These include type 1 diabetics and insulin-dependent type 2 diabetics.
For these groups, she asked CMS to allow for the annual or bi-annual beneficiary confirmation of the need for supplies, using an easy-to-use opt-in process.
“We believe lowering the number of times these beneficiaries will have to provide confirmation will ease unnecessary burden and ensure timely delivery of supplies,” she wrote. “One of the common beneficiary complaints CCS Medical receives is the number of calls and contacts that are made to obtain consent for and monitor usage of supplies.”
She also weighed in on the “misalignment” between shipping and billing CGM supplies. While CMS allows suppliers to ship 90 days’ worth of CGM supplies, it still requires suppliers to bill at 30-day increments.
“This requirement is burdensome to beneficiaries who do not want the additional contacts in the middle of the 90-day supply shipped,” she wrote in the letter. “In fact, they are often confused about why they are being contacted each month when they have months of supplies at hand.”
She noted to McKnight’s that this CGM billing rule stands in contrast to other Medicare Part B diabetes therapy supplies, such as insulin pumps and diabetes testing supplies, which allow for billing at 90-day periods. Compounding the confusion, CGM supplies work in tandem with insulin pumps.
“These systems work in together as the CGM is actually a supply of the pump because, for those on pump therapy, the pump is their CGM receiver,” she explained. “And what Medicare did was create two separate rules for how the billing works. So it’s really causing massive confusion.”
Langiotti sought to balance her criticism for the CGM billing discrepancy with praise for the proposed opening of the 14-day consent window.
“First of all, I do want to thank CMS for trying to do the right thing with these consent rules,” she told McKnight’s. “I think we need to acknowledge that they’re trying to fix the rules and minimize burden. And then I believe they really need to fix the 90-day, 30-day billing issue.”
Correction: The story incorrectly said “medication refills” in the second paragraph. It has been changed to “supply refills.” A couple of other clarifications also were made in the story.