November was National Homecare Month and also Chronic Obstructive Pulmonary Disease Awareness Month. During the month, days were set aside to recognize World COPD Awareness Day and the Great American Smokeout. These national health observances remind us of the growing respiratory patient population that we serve in home care and the increasing need for vigilance on legislative and regulatory fronts to ensure continued access to the critical services, equipment and care these patients rely on each and every day.
We enthusiastically participated in these observances. But in reality, we need to celebrate every month as National Homecare Month. And every day is COPD Awareness Day for oxygen providers and the patients they serve.
Close to one million Medicare beneficiaries receive home oxygen therapy to treat a variety of conditions that rob them of life-sustaining oxygen. The individual terror of no longer being able to breathe on your own is multiplying as the COPD population grows.
Unlike many other major chronic diseases, COPD is increasing in prevalence, not shrinking. An estimated 15 million Americans have been diagnosed with COPD, and perhaps another 15 to 20 million more may be undiagnosed. The National Institutes of Health estimate that in 2000, there were about 750,000 hospitalizations for COPD and about 1.5 million emergency room visits. And the annual cost for COPD during 2002 was approximately $32 billion in direct and indirect costs.
But in spite of the growing population in need of oxygen therapy, legislative and regulatory pressures are making it increasingly difficult to provide. Earlier this year, the CMS cut oxygen reimbursement as a part of the Medicare Modernization Act mandate to reduce reimbursement to levels consistent with the Federal Employees Health Benefits program.
To those unfamiliar, providing oxygen to home patients might seem like a simple process. This is not the case. During a visit from his congressman in August, Sam Clay of Clay Home Medical in Petersburg, Va., illustrated the volume of paperwork and complexity involved in providing oxygen and getting reimbursement for a Medicare beneficiary by spreading the paperwork and documentation required for a single beneficiary across a long table. This display was a simple reminder that providing oxygen to Medicare beneficiaries has a huge administrative component.
The respiratory sections of the DMEPOS supplier quality standards recently proposed by CMS and its contractor Abt Associates would add additional regulatory hurdles and burdens. Quality standards are mandated by the MMA to accompany the implementation of competitive bidding (aka restrictive contracting). As currently written, however, the standards focus too much on prescribing specific procedures rather than defining standards of care.
AAHomecare and other stakeholders carefully critiqued the proposed standards in comments to CMS last month. We strongly advocate quality standards. But they can be achieved without placing undue burdens on providers.
Barbara Rogers, a ventilator and oxygen user and the National Emphysema / COPD Association president, spoke at the September CMS Program Advisory and Oversight Committee meeting on the impact of the proposed respiratory standards. The medical equipment Barbara depends on, as she informed the panel, “are not commodities.”
Another hit to oxygen reimbursement may be on its way, since the Office of the Inspector General began conducting another oxygen study in November. We have urged the OIG to consider the services associated with oxygen provision, not only services documented for billing but also those for which documentation is not required or routinely maintained. Fortunately, to augment the survey process, OIG staff conducted site visits of several respiratory provider operations and saw firsthand the expertise and care that it takes to provide these critical and life-sustaining therapies.
Please continue to educate your members of Congress about the value and cost-effectiveness of home oxygen. It is important now, more than ever, to rally around our patients and speak with one voice on their behalf.
Kay Cox is president and CEO of the American Association for Homecare, Alexandria, Va. For more information about AAHomecare, visit www.aahomecare.org, or call 703/836-6263.
