NHIA Responds to Latest Flawed OIG Report Regarding Payment for Part B DME Infusion Drugs; Recommends Medicare Home Infusion Site of Care Act as Fix
Alexandria, VA—The National Home Infusion Association (NHIA) has responded to a September 2016 Health and Human Services Office of Inspector General (OIG) report on payment for Part B Durable Medical Equipment (DME) infusion drugs. NHIA believes that OIG's analysis of the payment for Part B DME infusion drugs is far too narrow to be the basis for new policy and recommends the Medicare Home Infusion Site of Care Act as a fix to Part B DME infusion drug reimbursement. In a letter to the OIG, NHIA stated its concern that the report incorrectly suggests that the home infusion industry is improperly driving over-utilization of milrinone lactate.
In the OIG report, entitled "CMS Should Address Medicare's Flawed Payment System for DME Infused Drugs, OEI-12-16-00340," dated September 2016, OIG incorrectly states that home infusion providers are pushing utilization. Home infusion providers fill prescriptions of milrinone lactate, a medication prescribed by physicians to treat heart failure only at the direction of the referring physician, thus precluding the industry from increasing utilization of this drug.
The issues that OIG addresses in this report, as well as its previous reports, regarding milrinone arise from the fact that currently infusion therapy is fully covered by Medicare in hospitals, skilled nursing facilities, hospital outpatient departments, and physician offices, but not in the home. Unlike comprehensive coverage found in the private sector, Medicare covers most infusion drugs, but not the infusion-related supplies, equipment, and services required to deliver the infusion therapy in the home setting.
NHIA has long sought a legislative fix for Part B DME infusion drug pricing and is urging Congress to pass the Medicare Home Infusion Site of Care Act, H.R. 605 and S. 275, as the appropriate policy to constructively fix how Part B DME infusion drugs are reimbursed. Additionally, NHIA has explicitly stated to OIG and Congress on several occasions that the application of the average sales price (ASP) methodology to Part B DME infusion drugs is acceptable as long as there is a payment included for the professional services that are essential for the safe and effective provision of infusion therapy in the home setting.
"OIG's analyses of this issue are only focused on the drug pricing methodology for Part B DME infusion drugs, and do not reflect any attempt to assess the impact of a drastic reduction in drug reimbursement on an accredited Part B supplier's ability to provide all of the essential components of care to patients who are often extremely ill and vulnerable," says NHIA President and CEO Tyler Wilson. "The recommendations included in this report, and similar past reports, should not be the basis or justification for regulatory or legislative action," he adds.
"NHIA remains extremely concerned that the OIG's recomm endations may trigger policies that would result in Medicare beneficiaries being incentivized to obtain infusion drugs in hospitals, skilled nursing facilities or hospital outpatient facilities," says NHIA Vice President of Legislative Affairs Ken Van Pool. "Receiving infusions in these sites of care would be at a far greater cost to the Medicare program and at a significant impact to a patient's quality of life," he says. The Medicare Home Infusion Site of Care Act represents a comprehensive solution to ensuring beneficiaries have access to a comprehensive home infusion benefit that covers the infused drugs as well as the supplies, equipment, and professional services.
Visit NHIA's website to learn more about the Medicare Home Infusion Site of Care Act and read NHIA's full response.
The National Home Infusion Association, based in Alexandria, Virginia, represents organizations that provide infusion and specialty pharmacy products and services to the entire spectrum of home-based patients as well as the interests of Medicare patients unable to get home infusion therapy. For more information, visit the Association at www.nhia.org.