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Request for Flexibility in Providing DMEPOS to Ensure COVID-19 Patients Receive Appropriate Care in the home

Thursday, March 26, 2020 @ 01:03 PM  posted by jbuytaert

The American Association for Homecare (AAHomecare), Midwest Association for Medical Equipment Services and Supplies (MAMES), National Coalition for Assistive & Rehab Technology (NCART), and VGM Group is writing to request that the state Medicaid Agency and any Medicaid Managed Care Organizations (MCO) make certain accommodations regarding the provision of durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS), and home infusion therapy, to enable DMEPOS suppliers to assist patients during the COVID-19 emergency.

MAMES is the regional association representing DMEPOS suppliers, manufacturers, and other stakeholders in the homecare community of Minnesota and 7 other states in the Midwest: IA, KS, MO, NE, ND, SD and WI. Our members are in patients’ homes every day and are uniquely qualified to be able to assist during the COVID-19 pandemic.

DME providers serve millions of Medicare and Medicaid beneficiaries in their homes; and that number continues to grow significantly with the spread of the COVID-19 virus. Our members supply home oxygen therapy, ventilator services, and many other necessary items and services that allow patients to be released from hospitals, nursing homes and other health care facilities to complete their recovery.

The current COVID-19 outbreak presents many challenges to our health care system with Hospitals needing to be discharging increased numbers of patients into their homes to prevent exposure and to free up resources and hospital beds. This is putting a strain on the provision of DME Items and services, particularly for suppliers of DMEPOS providers.

There are a number of “red tape” issues that can be alleviated today, to ensure that patients with acute conditions can access medically necessary home ventilator and home oxygen therapy, and other DMEPOS items and services. Listed below are recommendations which will allow the DMEPOS industry to focus on current emergency patient situations.

MAMES learned that DHS submitted an 1135 waiver to CMS for flexibility to respond to COVID-19 on March 25, 2020.

CMS and state Medicaid programs have multiple legal authorities to implement programmatic waivers, including those based on Section 1135 of the Social Security Act. In addition, CMS’s March 17, 2020 announcement of broadened access to telehealth services can facilitate/expedite some provision of DMEPOS care. We are aware of additional waiver authorities that CMS and the state can utilize to implement.

Time is of the essence. The faster our members can be assured that these modifications can be accommodated, the faster many beneficiaries will have access to medically necessary home ventilation and oxygen therapy, and other DMEPOS items and services. Our policy recommendations to state Medicaid agencies and MCO plans are as follows:

1. Waive any face to face requirements if prescriber couldn’t or wouldn’t do an office visit and allow telehealth visits to meet requirements while waiving the video component. Recent federal guidance to reduce barriers to telehealth services are a step in the right direction.

2. Delay the implementation of the new incontinence policy that was to go into effect 4/1 until 10/1/2020.

3. Waive all prior authorization and re-authorization requirements for all DMEPOS items, supplies and repairs.

4. Waive prior authorization requirements for exceeding quantity limitations on gloves, incontinence, urological, ostomy, suction, ventilators, enteral, and wound care supplies.

5. Waive signature requirements for proof of delivery on HME items; including allowance of text, email, photographic, or confirmed shipment receipt from third-party carrier evidence to validate proof of delivery during COVID-19 crisis.

6. Allow an extension of the expiration date of written orders/prescriptions for an additional nine months from the date orders currently expire, for recurring medical supply orders and on-going DME rental claims.

7. Allow for coverage and reimburse equipment, supplies, and services provided to patients with a confirmed COVID-19 diagnosis.

8. Allow in home sleep testing through an independent testing facility (IDTF) to qualify beneficiaries for PAP devices.

9. Allow additional oxygen, PAP, ventilator, and suction supplies for patients who become sick or diagnosed with COVID-19.

10. Allow any requirements for clinician and/or Assistive Technology Professional in-person engagement for complex rehab wheelchairs and accessories to be met through the use of remote technology.

11. Allow Prescribers not currently enrolled in Medicaid programs to order DMEPOS

12. Require Medicaid and Medicaid MCO plans suspend all audits to allow DMEPOS suppliers to focus on their emergency activities until this pandemic resolves.

It is imperative that provider cashflow is not interrupted to ensure providers are able to continue servicing patients in this time of need. Claims adjudication and processing must occur on normal schedule.

We appreciate your prompt attention to these issues. Many of our members are already implementing these types of measures to ensure that beneficiaries can access appropriate medical care in their homes. Communities across the nation are dealing with a rapidly accelerating crisis that will test our health care systems like never before. DMEPOS suppliers are in a unique position to provide home ventilation and oxygen therapy that can make a significant difference in alleviating hospital overloads and facilitate the ability of beneficiaries to recover in their homes, the safest and most cost-effective site of care: the home.

We thank you for all the efforts being made related to access to medically necessary equipment, supplies and medication for beneficiaries during the COVID-19 outbreak. We welcome the opportunity to discuss any of the requests outlined above. Please let us know if there is any other information we can provide.

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