Congress: Act to Fix Shortsighted Home Respiratory Therapy Cuts
Although healthcare and payment policies aimed at improving the strength and longevity of the Medicare program are easy for providers, taxpayers, and lawmakers to stand behind, when those policies fall short – disrupting the care of patients who need it the most – there’s no time to delay in finding a solution.
A timely solution, and stabilization of an extremely tenuous situation, is certainly called for when it comes to the Center for Medicare & Medicaid Services’ (CMS) steep cuts to home respiratory therapy as part of its payment reductions for Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) – the latest of which went into effect July 1.
Since January, an accelerated timeline and the application of urban competitive bid rates in traditionally rural, non-competitive bid areas has slashed 30-50 percent from provider reimbursement for essential respiratory services, according to an internal analysis by the Council for Quality Respiratory Care of publicly released 2015 fee schedule rates compared to the 2016 modified fee schedule rates. Those drastic reductions failed to account for the cost of the equipment, supplies, or services provided, and were also applied in areas that the Congress indicated should not be subjected to competitive bidding.
Both providers and suppliers are on edge due to fears that these reductions could undermine the delivery of quality patient care. While CMS claims there is no patient impact, this conclusion is based on a mere four months’ worth of data. This is why the Council for Quality Respiratory Care is calling on Congress to take legislative action to ensure patient care is not at risk.
Just how important are these types of services? Very. Millions of Americans can’t breathe without them.
Chronic Obstructive Pulmonary Disease (COPD) – a group of respiratory illnesses which includes chronic bronchitis and emphysema – has been diagnosed in an estimated 15 million Americans nationwide, and is the third leading cause of death in the United States, affecting 12 percent of Medicare beneficiaries. For these patients, home oxygen therapy, sophisticated delivery devices, and related respiratory care aren’t simply optional, ancillary services. Without these services and related equipment, the body can’t take in enough oxygen, which at its worst can be fatal.
It’s a terrifying prospect for patients and their providers – and one that only Congress can prevent from snowballing as the full impact of these cuts reverberates nationwide.
Already, CMS’ experiment with this rapid payment reform has created shockwaves felt by some of Medicare’s most vulnerable patients. Home respiratory suppliers across the country have reported reductions in their service areas and changes to the type of care they are able to offer. Some suppliers for example, are no longer providing certain equipment to Medicare patients, have been forced to eliminate the delivery of supplies, and are reducing access to respiratory therapists beyond the minimum required by law. However, most are trying to hold on and protect their patients, hoping Congress will enact common sense legislation to extend the initial phase-in period and review the method by which these rates were set.
The rates enacted July 1 reflect the outcome of the competitive bidding program. These rates are not only inappropriate to apply to noncompetitive bidding areas (they do not reflect the geographic, labor, and other cost differences between extremely urban competitive bidding areas and the rest of the country), but also because the methodology used to establish the competitive bidding rate has been called into question. Even the most recent CMS proposed rule includes measures to fix a problem that is the result of this flawed methodology. There are many problems with the methodology and Congress and the CMS must correct them. In the meantime, these rates alone should not be rolled out nationwide.
Reform that prevents inappropriately high reimbursement for care – for the benefit of the Medicare program and for taxpayers – is a goal that we can all enthusiastically support. But what we cannot – and must not – do is force a substantial cut based on a flawed methodology that will in all likelihood disrupt patient care, lead to increased hospitalizations and complications, and undermine the savings CMS hopes to achieve.
Instead, the nation’s home respiratory therapy suppliers hope that Congress and CMS will truly and carefully evaluate the impact to patients over more than four months. The very nature of chronic diseases, and how respiratory illnesses progress, demands at least a year of evidence to show how payment rate reductions will affect overall patient care and outcomes.
In the absence of this critical data, a better solution than drastic and harmful cuts are value-based reforms that improve efficiencies, reduce costs, and protect patient care. As we are seeing elsewhere in Medicare, the future depends on our ability to work together and enhance care coordination, disease management programs, and focus on outcomes – rather than equipment and supplies.
Congress has a short window of time to act, during which we are urging them to pass legislation to provide much needed relief to home oxygen therapy providers by extending the phase-in of cuts well past the July 1 date on which cuts were fully implemented. Allowing more time for us to fully understand the consequences of these cuts will also offer us more time to work with policy makers to craft solutions to reduce costs while also enhancing quality care and protecting patient access.
Preparing for Medicare’s future indeed requires reform and action – but not at the expense of patients who depend on us for the very breath they need to survive.