NHIA: “Disappointed” in CMS Home Health Proposed Rule for CY 2024

• By Laurie Watanabe
• Jul 13, 2023

The National Home Infusion Association (NHIA) said it’s “disappointed” — but not surprised — by how the Centers for Medicare & Medicaid Services (CMS) addressed home infusion therapy in its proposed updates to the Medicare Home Health Prospective Payment system for calendar year (CY) 2024.

In a July 3 news announcement, NHIA addressed CMS’s proposed updates, released on June 30.

“The proposed home health rule does not address home infusion therapy (HIT) services other than to describe the potential interaction with the new Home IVIG Items and Service benefit, which replaces the IVIG demonstration starting on January 1, 2024,” NHIA said.

“As NHIA expected, the permanent Home IVIG Items and Service benefit will mimic the demonstration. The description of the long-standing IVIG demonstration code, Q2052, will be modified and it will continue to be used for the permanent benefit. The payment allowable calculation will continue to be based on the LUPA rate. CMS is proposing a rate 2.7-percent higher than the 2023 demonstration rate, $408.23*1.027= $419.25. As in the demonstration, Q2052 must be billed to the DME MAC by same entity providing the immunoglobulin drug. The DME MACs will incorporate the home IVIG items and services payment into the IVIg LCD and related Policy Article, which should facilitate a smooth transition.”

The organization added that it is “disappointed” that CMS “seems satisfied with the lack of access and utilization to home infusion therapy services and has once again neglected to take steps to improve the benefit. Home infusion has great potential to lower Medicare spending while improving the quality of life for beneficiaries with disabilities, those with transportation challenges, and lack of infusion access in their rural communities.”

NHIA said it will submit comments on the proposed updates and reiterated its support for the Preserving Patient Access to Home Infusion Act bills currently in the U.S. House and Senate.