Disposable NPWT Payment
Tuesday, September 27, 2016
Posted by: Becky Carroll
CMS Releases Proposed Rule on Disposable Negative Pressure Wound Therapy Payment
Legislation was passed in late 2015 to allow for payment of disposable negative pressure wound therapy devices in the home health setting. The payment would be equal to the payment that currently exists for such devices in the outpatient setting, including the professional services provided. A "disposable device" is defined as: a disposable negative pressure wound therapy device that is an integrated system comprised of a non-manual vacuum pump, a receptacle for collecting exudate, and dressings for the purposes of wound therapy; and (B) a substitute for, and used in lieu of, a negative pressure wound therapy durable medical equipment item that is an integrated system of a negative pressure vacuum pump, a separate exudate collection canister, and dressings that would otherwise be covered for individuals for such wound therapy.
The provision also calls for the Government Accountability Office (GAO) to study the impact of payment for such disposable devices, including the types of disposable devices that could potentially qualify as substitutes. Additionally GAO must report on the views and information from manufactures, providers and suppliers on the incentives and disincentives under current Medicare coverage and payment policies; the implications of expanding Medicare coverage to include additional disposable devices that are substitutes for other types of DME and different payment methodologies. The report is due 18 months after the enactment. In addition, the GAO is also required to study the impact on utilization, the type of Medicare beneficiaries under the home health benefit who use the disposable devices compared to the substitute DME, and payment rates of other payers including Medicaid. The second report is due in four years. The WOCN Society will follow this study closely and participate in whatever means are deemed appropriate.
In June, CMS released its proposed payment policy for how disposables will be paid for in the home health setting. CMS has proposed to pay the separate payment amount for NPWT, using a disposable system, to be set equal to the amount of the payment that would be made under the Medicare Hospital Outpatient Prospective Payment System (OPPS) using the Level I Healthcare Common Procedure Coding System (HCPCS) code, otherwise referred to as Current Procedural Terminology (CPT-4) codes, for which the description for a professional service includes the furnishing of such a device.
Under the OPPS, CPT codes 97607 and 97608 (APC 5052—Level 2 Skin Procedures), include furnishing the service as well as the disposable NPWT device. The codes are defined as follows:
- HCPCS 97607—Negative pressure wound therapy, (for example, vacuum assisted drainage collection), utilizing disposable, non-durable medical equipment including provision of exudate management collection system, topical application(s), wound assessment, and instructions for ongoing care, per session; total wound(s) surface area less than or equal to 50 square centimeters.
- HCPCS 97608—Negative pressure wound therapy, (for example, vacuum assisted drainage collection), utilizing disposable, non-durable medical equipment including provision of exudate management collection system, topical application(s), wound assessment, and instructions for ongoing care, per session; total wound(s) surface area greater than 50 square centimeters.
However, CMS has proposed not to pay for the services of home health providers who administer disposable NPWT to their patients. Specifically, CMS states the following: "CMS is proposing that for instances where the sole purpose for an HHA visit is to furnish NPWT using a disposable device, Medicare will not pay for the visit under the HH PPS. Instead, we propose that since furnishing NPWT using a disposable device for a patient under a home health plan of care is to be paid separately, based on the OPPS amount, which includes payment for both the device and furnishing the service, the HHA must bill these visits separately under type of bill 34x (used for patients not under a HH plan of care, Part B medical and other health services, and osteoporosis injections) along with the appropriate HCPCS code (97607 or 97608). Visits performed solely for the purposes of furnishing NPWT using a disposable device are not to be reported on the HH PPS claim (type of bill 32x)."
The WOCN Society is very concerned with this proposed and has provided CMS with detailed comments about their refusal to pay for provider services. Those comments can be view here.