AAH comments on rates 

WASHINGTON – Rates in former competitive bidding areas should be based on a 90/10 blended payment formula, AAHomecare argues in its comments to CMS’s recent DMEPOS Proposed Rule. 

“The 90% should be based on the current payment rates in former CBAs, and the 10% should be based on the 2015 unadjusted fee schedule,” the association says. 

Non-rural, non-CBAs should be based on a 75/25 blended payment formula, with the 75% based on the current rates in the former CBAs and the 25% based on the unadjusted fee schedule, AAHomecare also argues. 

Other recommendations in the association’s comments: 

• CMS should eliminate its proposed limit on the number of times an applicant can resubmit applications for new or revised Level II HCPCS codes, as long as the applicant includes new data/information to support the request. 
• CMS should add to its HCPCS code panel representatives from state Medicaid programs, and/or representatives from the National Association of Medicaid Directors, and representatives of commercial payers. 
• CMS should incorporate into its HCPCS code application process a public notice and comment for its gap-filling and compatibility analyses after a positive preliminary HCPCS code decision. 
• CMS should permanently exempt accessories used with complex manual wheelchairs from competitive bid-derived pricing. 
• CMS should address a number of outstanding implications related to its proposal to expand coverage for adjunctive continuous glucose monitors and should allow for public comment on those issues. 

To read AAH’s comments in full, go here. 

To read a summary of the proposed rule, go here.