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CQRC Concerned with Inclusion of Home Ventilators in Competitive Bidding Program

CQRC reiterates its support for much-needed reforms to Competitive Bidding Program (CBP), but opposes the inclusion of home ventilators out of concern for vulnerable patient population.

Washington, DC, December 05, 2018 --( The Council for Quality Respiratory Care (CQRC) – a coalition of the nation's leading home oxygen therapy provider and manufacturing companies – today reiterated its support for the Centers for Medicare & Medicaid Services’ key reforms to stabilize the market for Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) including home respiratory therapy and supplies, but expressed concern over a sub-regulatory proposal to include home ventilators in the Competitive Bidding Program (CBP).

In a letter to CMS Administrator Seema Verma, the CQRC praised CMS for reforming the CBP so the price of DMEPOS is determined using a lead-item pricing methodology, rather than the flawed median bid methodology, which caused half of all providers to accept reimbursement rates below their maximum bids.

However, the letter expressed serious reservations about the inclusion of home ventilators in the CBP because of concern about whether the new program would be interpreted to incorporate home ventilators, which are used by the most fragile home respiratory beneficiaries.

“The CQRC is deeply troubled and confused by the proposal to add three types of ventilation devices, which are used by highly vulnerable Medicare beneficiaries who otherwise could not remain in their homes, to the competitive bidding program before the modified policies have been implemented,” the letter states.

Advancements in home ventilation have helped improve the quality of life and healthcare outcomes for Medicare beneficiaries who require such treatments to survive and would otherwise rely on institutionalized care. In addition to allowing patients to be treated in the comfort of their own homes, the letter highlights research that shows the use of non-invasive ventilators has created clinical benefits that lower rates of morbidity and mortality, as well as a reduction in Part A costs.

Unfortunately, the inclusion of home ventilators in the CBP could impede patient access to these lifesaving therapies by requiring these patients to rely upon the lowest bidders before the new methodology has been tested. As CMS starts to implement reforms that make it more likely for home oxygen supplies and equipment to reflect true market pricing, it is unclear how the updated CBP methodology will address unresolved issues, such as capacity, how information will be used to set rates, and the relationship between lead items and non-lead items in each product category. Moreover, researchers have argued that one of the rationales for subjecting home ventilators to competitive bidding -- concerns about overutilization -- is largely unfounded as the recent rise in usage is owed far more to technological and clinical advancements than fraudulent overutilization.

Therefore, the CQRC argues it would not be appropriate for the Competitive Bidding Program to set rates for home ventilation at this time.

“It is premature to subject a vulnerable population that will die without access to home ventilation therapy to the growing pains the new methodology will cause during the first rounds of its implementation,” the letter said.

About the Council for Quality Respiratory Care
The CQRC is a coalition of the nation's seven leading home oxygen therapy provider and manufacturing companies. To learn more, visit and follow CQRC on Twitter at @TheCQRC.
Contact Information
The Council for Quality Respiratory Care
Ellen Almond

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