Payment for Disposable NPWT
Thursday, November 3, 2016
Posted by: Becky Carroll
Payment for Disposable NPWT in Home Care Setting Finalized
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 June 2016, CMS released its proposed payment policy for how disposables will be paid for in the home health setting. CMS proposed not to pay for the services of home health providers who administer disposable NPWT to their patients. The WOCN Society was concerned with how CMS has proposed not to pay for provider services, those comments can be view here.
Unfortunately, CMS did not change their proposal and have finalized that nursing services will not be paid for during visits. The final language reads like this: “A separate payment will be made to a HHA for furnishing NPWT using a disposable device to an individual who receives home health services for which payment is made under the Medicare home health benefit, for services furnished beginning January 1, 2017. The payment amount for furnishing NPWT using a disposable device under a HH plan of care will be equal to the lesser of the actual charges or the OPPS payment amount for CPT® codes 97607 and 97608, and must be billed via the 34x TOB. HHAs may not bill for furnishing NPWT using a disposable device on a TOB 32x. Payment for HH visits related to wound care, but not requiring the furnishing of an entirely new disposable NPWT device, will still be covered by the HH PPS episode payment and must be billed using TOB 32x. Where a home health visit is exclusively for the purpose of furnishing NPWT using a disposable device, the HHA will submit only a TOB 34x. Where, however, the home health visit includes the provision of other home health services in addition to, and separate from, furnishing NPWT using a disposable device, the HHA will submit both a TOB 32x and TOB 34x—the TOB 32x for other home health services and the TOB 34x for furnishing NPWT using a disposable device. Physical therapists, occupational therapists, registered nurses, and licensed practical nurses are permitted to provide NPWT using a disposable device under a home health plan of care.”
The WOCN Society will continue to work with CMS on this issue and we would encourage members to review the final rule as it outlines a number of different scenarios in which members will be interacting with patients, and provides guidance on how those visits will be billed. The final rule from CMS can be located here.