The next 12 months are sizing up to be ones that will provide real opportunities to advance industry priorities. At press time, two legislative initiatives—the competitive bidding alternative and the complex rehab technology (CRT) separate benefit legislation—were still pending action by Congress. Both issues are multifaceted and will remain priorities in 2014 regardless of what Congress does or does not do by the end of 2013. In addition, 2014 is an election year and legislators tend to be more attuned to the concerns of their constituents. Therefore, let’s evaluate the primary opportunities for 2014, identifying what actions will be necessary in order to advance. Competitive Bidding—While uncertainty remains as to how Congress will modify the Medicare bidding program late in 2013, support has never been stronger for an alternative to fix the most egregious flaws within the current program and require Medicare to follow its own licensing and accreditation rules. Regardless of when Congress acts to fix certain elements of the program, regulations or sub-regulatory guidance will most likely be necessary in order implement the changes. Opportunities to influence should exist, so it will continue to be important for stakeholders to remain engaged and ready to act. Separate Benefit for Complex Rehab Technology—The complex rehab industry has never been better positioned to pass legislation to create a separate benefit category for complex rehab. H.R. 942 and its Senate companion bill S.948 are bipartisan and have strong consumer and clinician support. The legislation is designed to improve and protect access to complex rehab technology (CRT) products and services for individuals with significant disabilities and medical conditions. Among other things, the legislation would further protect the complex rehab technology industry from future arbitrary payment reductions and provide a more formal mechanism for future payment enhancements. Once the legislation is passed, the rather lengthy regulatory process will follow. This will be a big industry focus in 2014. For the latest information on this initiative, visit access2CRT.org. CMS E-Doc Initiative—The much-anticipated Medicare pilot project for the electronic Determination of Coverage (eDoC) for PMDs is set to begin in 2014. You may recall this effort started with a series of CMS conference calls on an “e-clinical template” in 2012. The electronic eDoC power mobility device (PMD) user story (framework of requirements for a determination of coverage) was approved on Oct. 30, 2013, which allows the project to proceed toward preparation for the pilot phase. The purpose of the pilot phase is to implement the technology in real-world situations and aid in learning the policies that will be required for an operational system according to the Standards and Interoperability framework. At press time, no set dates for the rollout were published, but it is expected to occur in 2014. Medicaid—Challenges will continue to present themselves at the state level as legislatures continue to look for ways to reduce expenditures or slow the growth of their Medicaid programs. The industry is much more organized and has made some progress in certain states due to increased industry efforts on Medicaid issues. In 2014, many state legislators will also be up for re-election, which should result in them being more attuned to concerns or issues raised by constituents. They will be looking for ways to help, and there are certainly things they could do to facilitate improvements within the Medicaid program. Since all states have somewhat individual Medicaid programs, the best resource for the latest information is your state association and organizations like NCART on the complex rehab front. Each has resources to get stakeholders more involved in helping protect Medi- caid coverage and payment policies that may be under discussion for further reductions. It is going to be another busy year, ripe with opportunities to advance positive outcomes. If we, as an industry, continue to build on the significant education and lobbying efforts with policy makers, legislators, consumer groups, clinician groups, and other stakeholders, I am confident 2014 will be a better year.
A glance at what’s on the horizon for providers in the coming year
Thursday, December 26, 2013