What’s the Latest on Transitional Payment Reform


NHIA has been working on several fronts to address CMS’ misguided policy on home infusion professional services payment. Below is a summary of recent activities:

  • In December, NHIA submitted comments to CMS as part of their extended comment period on the definition of infusion drug administration calendar day. NHIA recommended a compromise definition that would allow infusion providers to get reimbursed on days when pharmacy-related professional services are rendered. Those services could include initial and ongoing assessment, plan of care development and refinement, drug preparation, and care coordination.

  • CMS also recently ruled that home health agencies could bill for infusion-related nursing services under a home health episode of care. This led to questions about whether and how home infusion companies could bill for home infusion professional services for patients who were also receiving home health. NHIA met with CMS staff to discuss the challenges of this interpretation and to get guidance on how home infusion providers should bill under these circumstances. CMS is working on a response.

  • NHIA also continues to pursue legislative relief that would allow for reimbursement for remote professional services. We have been working with the Senate Finance Committee, House Ways and Means Committee, House Energy and Commerce Committee and other home infusion champions to finalize the policy, assess the cost to the government and identify potential pay-fors. Unfortunately, legislative action has been delayed by the government shutdown and it is unclear how quickly congress might act on this issue.

  • Finally, NHIA is preparing to take legal action against CMS to challenge the Agency’s interpretation of “infusion drug administration calendar day,” which limits payment to only those days in which a “skilled professional is in the patient’s home.” A claim could be filed as soon as mid-February.