Congress finally made some progress towards providing home infusion services to Medicare patients back in 2017 when they passed the 20th Century Cures Act. They opened up the opportunity for patients with heart failure, cancer, and the immunocompromised (billed under Part B) to get services through an agency such as Infusion Solutions. Patients love this, and it saves Medicare money versus sending these patients to more costly sites of care such as skilled nursing homes or hospitals. This benefit is slated to begin in January 2019.
But CMS (Center for Medicare Services), the government body that implements the aforementioned law, is interpreting Cures in a vastly different way then what Congress intended. In short, they are suggesting that reimbursement for home infusion is only billable on the day when an RN shows up at the residence to do the infusion, which is generally once per week. This reading of the law disregards the “behind-the-scenes” professional services that go into managing patients the other 6 days of the week, including sterile compounding of medications, care management, pharmacy services, lab reviews, updates to the patient plan of care, and more. If CMS doe not change the way they implement the Cures Act, it will essentially eradicate the home infusion benefit that Congress specifically wrote the law to protect. No infusion company can survive on one billable day of service.
All of this is quite baffling and a bit hard to believe.
BUT…all is not lost. We are in the last stages of the comment period for CMS, and so they need to hear from YOU. Voice your concerns to CMS and to your members of Congress, and tell them to get this right for patients. It is critically important to do this NOW, as the comment period ends on Aug 31st.
Below is a link to a site which will allow you to do just that. Take a moment to make your voice heard. Feel free to customize the letter (that is impactful) but if you do, make sure your letter contains the following sentiment:
CMS should define “infusion drug administration calendar day,” for both the temporary and the permanent payment, to include the broader set of professional services including pharmacy services (such as drug preparation and dispensing), case management, nursing services, and other professional services. CMS also should broadly define infusion drug administration calendar day to include “home infusion professional services” and remove the physical presence requirement.
Got it? Good! NOW GO DO IT!