‘There needs to be a way to recognize a patient as being part of PHE’

WASHINGTON – Industry stakeholders are trying to guide what a post-PHE world for home oxygen therapy and other product categories might look like. 

AAHomecare recently discussed with CMS a one-page recommended reference document for Medicare audit contractors reviewing claims for dates of service during and after the PHE. The document is a cheat sheet of sorts for the waivers that have been in place during the PHE that don’t require, for example, medical documentation or a signature. 

“It shows, if a patient was set up during the PHE, these are things you should look for and these are things you shouldn’t look for,” said Kim Brummett, vice president of regulatory affairs. “There needs to be a way to recognize a patient as being part of the PHE.” 

The meeting with CMS went well, Brummett says, but AAHomecare needs to further revise the document to reflect the agency’s feedback. Consideration also has to be given for those patients set up prior to the PHE and yet could not meet on-going requirements, in addition to those set up during the PHE. 

Indeed, there are two issues at play, says Andrea Stark, a Medicare consultant and reimbursement specialist for MiraVista. The first involves items that were capped or were reimbursed entirely during the PHE. 

“CMS can’t expect providers to cure documentation and support on a retroactive basis,” she said. “That’s the guidance I’m looking for there.” 

The second issue, however, is less clear, Stark says. 

“For patients where clinical indications were bent to meet that patient uniquely and the rental and resupply claims extend beyond the PHE – those are the ones where the industry needs the greatest guidance,” she says. 

Of course, the other question is, when the PHE does end, what will be the onramp for CMS re-implementing requirements like the face-to-face and re-certification.   

“Think about all the patients that are going to need to go back to the doctor,” Brummett said. “How many patients can they see and how quickly? Doctors aren’t going to see tens of thousands of patients in six months, never mind 60 days.” 

The PHE is in place until mid-July and will likely be extended at least one more time through mid-October to keep it from becoming an election issue, but the wheels at CMS are turning, Brummett says. 

“They’re starting to have conversations about it,” she said. “If we can be proactive as much as we can be, we’ll get closer to something that would work for the industry.”