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Michigan RT's,

    Medicare is considering placing home ventilators into the Competitive Bid Program.  Home ventilators are very expensive and require costly maintenance and follow up.  A home ventilator program is not a product, but rather a program of care that requires intense training and continued support.  If Medicare places ventilators into the Competitive Bid Program most home care companies will be forced to decrease their level of care and/or not provide the service at all.  This will be harmful to the patient and limit access to vital medical equipment.  Please consider the following bullet points.

  • In January 2016 CMS changed the ventilator HCPCS codes and dramatically reduced the reimbursement rate, by as much as 35%.
  • The explanation provided by CMS for the drastic reimbursement cuts was an increase in utilization of previous code E0464-Non-invasive ventilation.
  • Ventilation is a life-sustaining intervention provided when the patient’s spontaneous ventilation is inadequate to support life.
  • Very few HME companies provide ventilation products & services.
  • Only the sickest patients qualify for these products, and they are used as a last resort.
  • The cost to HME companies to provide this type of care includes, but is not limited to, the employment of highly trained and skilled, licensed staff, quality & reliable equipment, initial and continued caregiver training, regular non-reimbursable home visits.
  • The competitive bid process biases winning bids toward lower cost and lower quality medical equipment.
  • The reduction in the reimbursement rates due to the competitive bid process will jeopardize the ability of HME companies to provide ventilation.
  • This would mean more patients remaining in facilities and reduce patients’ access to affordable and quality home ventilator care.
  • Relying on the competitive bid process to provide for our most fragile patients is not appropriate.

    Please submit a comment to Medicare at  DMEPOS@cms.hhs.gov. In order for your comment to be considered, you must type “Competitive Bidding Product Categories” as the subject line for your email. Only comments submitted by 11:59:59 PM Prevailing Eastern Time on December 17, 2018, with the subject line above, will be considered.

 

William Hart, BAS, LRRT

Director of Clinical Services

Advent Home Medical

Click here to see the letter the AARC president wrote in response to home ventilators being placed in the Competitive Bid Program.


 

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