Home infusion stakeholders roll up sleeves on NCD

WASHINGTON - Home infusion stakeholders will meet with Medicare officials this week to begin digging into how CMS's national coverage determination for parenteral and enteral nutrition will replace existing local coverage determinations.

CMS announced earlier this month that it will retire the LCDs, which stakeholders says are some of the “most complicated” within the DMEPOS world, on Nov. 12.

“There are lots of details and decision trees to qualify a patient—situations A through H—and each has different criteria,” said Bill Noyes, senior vice president of reimbursement policy for the National Home Infusion Association. “The LCDs also called for various tests that are considered obsolete and not performed at any medical centers.”

The NHIA has argued for years that the LCDs limit access to parenteral and enteral nutrition. Most recently in July, the association and the American Society of Parenteral and Enteral Nutrition held an informal meeting with the DME MAC medical directors to highlight the outdated coverage guidelines.

The more general nature of the NCD, however, raises the question: How will the DME MACs and other auditing entities interpret the qualification of patients? As it stands, the NCD relies on physicians to determine medical necessity based on the patient's clinical condition.

“There's a lot of detail—we are just digging into it,” he said. “We are advocating for the MACs to educate. I think the qualifying criteria will exist in a combination of billing and coding guidance, along with NCD.”