Advocating for Increased Supplies in State Medicaid Programs

On June 30, 2023, the Centers for Medicare & Medicaid Services (CMS) issued the calendar year (CY) 2024 Home Health Prospective Payment System (HH PPS) Rate Update proposed rule, which would update Medicare payment policies and rates for Home Health Agencies (HHAs). This rule included two recently enacted proposed policy implementations for WOCN priorities: The Lymphedema Treatment Act and the Better Wound Care at Home Act. WOCN will be reviewing the proposed rule and providing comments back to CMS regarding their proposed implementation. The regard to lymphedema the rule makes the following proposal:

This rule would address the scope of the new Medicare Part B benefit for standard and custom-fitted gradient compression garments and other compression treatment items benefit by defining what constitutes a standard- or custom-fitted gradient compression garment and identifying other compression items used for the treatment of lymphedema that would fall under the new benefit category, beginning January 1, 2024. The rule proposes that Medicare would cover gradient compression garments for both daytime and nighttime use as well as ready-to-wear, non-elastic, gradient compression wraps with adjustable straps, and compression bandaging systems applied in a clinical setting as part of phase one decongestive therapy.

This rule would establish the initial Healthcare Common Procedure Coding System (HCPCS) codes and the payment methodology for these items and propose how future coding, benefit category, and payment determinations for these items would be made. The proposed payment basis for lymphedema compression treatment items is the average Medicaid State agency payment amounts plus 20 percent. In the event that Medicaid State agency payment rates are not available, this rule proposes to base payment rates on the average of TRICARE and internet retail prices. If neither Medicaid nor TRICARE payment amounts are available, this rule proposes to base Medicare payment rates on the average internet retail prices for a lymphedema compression treatment item.

To address Congressionally approved changes to disposable negative pressure wound therapy (NPWT) devices, CMS will make the following changes:

• The payment amount for CY 2024 would be set equal to the amount of $263.25 updated by the percent increase in the CPI–U for the 12-month period ending in June of 2023.
• We are also proposing that claims reported for a dNPWT device would no longer be reported on TOB 34x. Instead, for dates of service beginning on or after January 1, 2024, the HHA would report the Healthcare Common Procedure Coding System (HCPCS) code A9272 (for the device only) on the home health type of bill TOB 32. The code HCPCS A9272 is defined as a wound suction, disposable, includes dressing, all accessories and components, any type, each. We will provide education and develop materials outlining the new billing procedures for dNPWT under the home health benefit including MLN Matters® articles and manual guidance after publication of the CY 2024 HH PPS final rule.
• We are also proposing that the services related to the application of the device would be included in the HH PPS and would be excluded from the separate payment amount for the device. In addition, only the home health services for the administration of the device would be geographically adjusted and the payment amount for HCPCS A9272 would not be subject to geographic adjustment.