Patient Access To Quality Care Concerns For Home Oxygen Therapy
The Council for Quality Respiratory Care expressed concern regarding the Centers for Medicare and Medicaid Services final rule on competitive bidding.
The rule establishes requirements for accreditation of Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) suppliers and lays the groundwork for implementation of the Medicare DMEPOS Competitive Bidding Program.
This new program includes oxygen equipment and supplies, respiratory assist devices and continuous positive airway press devices and accessories, as well as sleep apnea services, supplies and equipment. The competitive bidding process could jeopardize the level of quality of care for services the patients would normally receive, thereby destabilizing the benefit and providers alike. The new bidding process is based solely on price, thereby excluding therapy-related services and patient-support services essential to the delivery of quality care.
The winning bid will simply result in the "lowest common denominator" and not take into account these critical services. In addition, it discourages the use of higher-priced innovative technologies that government and health officials have supported in separate rule-making. The new bidding process risks sacrificing these critical components of the home oxygen therapy benefit that, taken together, encourage patient mobility, prolong quality of life, and can result in reduced need for hospital stays and reduced costs to taxpayers in the long run. Further, the CQRC supports stronger quality standards than the accreditation requirements outlined in the Final Rule, noting that the Final Rule does not include performance as a factor in the bidding process.
Peter Kelly, Chairman of the CQRC and CEO of Pacific Pulmonary Services, said, "The Medicare home oxygen benefit provides home oxygen therapy for patients suffering from Chronic Obstructive Pulmonary Disease (COPD), which is regarded as the fourth leading cause of death in the United States. Under this Final Rule, lower quality standards than what the CQRC supports, coupled with a bid structure that is designed solely to minimize upfront costs, induces providers to sacrifice service levels and quality of care to maintain price competitiveness, directly affecting quality and threatening safeguards. In addition, the competitive bidding process does not provide adequately for innovative new technologies and necessary patient services, both of which can improve patient outcomes and dramatically reduce Medicare costs.
Despite CMS' aggressive savings estimates, the massive DMEPOS cuts to the home oxygen benefit the past several years and also coming in 2009 have largely accounted for the savings expected from competitive bidding, increasing the likelihood the program will cost more to administer than it will save. As providers who deliver cost-effective, life-enhancing care to approximately 650,000 frail, elderly and chronically ill individuals, where service and continuity of care are essential to their well being, we simply can't risk the introduction of a complicated, costly program that seeks to maximize savings at the expense of service levels and quality of care. Especially at a time when home oxygen providers are trying to adjust to massive cuts resulting from the Medicare Modernization Act of 2003 and the Deficit Reduction Act of 2005 which are only now being realized."
"Changes to this benefit have the potential to disrupt the quality and continuity of care for our patients," said Mark Shreve, CEO of the Coalition for Pulmonary Fibrosis, which represents more than 128,000 patients who suffer from idiopathic pulmonary fibrosis (IPF), a progressive and ultimately fatal lung disease for which oxygen is a critical component of treatment. "The rule announced Monday by CMS may limit a patient's access to the services they need to survive, which is unacceptable."
Thomas Petty, M.D. an internationally-renowned pioneer in the field of home oxygen therapy and current Professor of Medicine, University of Colorado, Denver, and Professor of Medicine, Rush Presbyterian St. Luke's Medical Center, Chicago said the following in response to the new competitive bidding program: "As the initiator of the Long-Term Oxygen Treatment Trial (LOTT) 40 years ago, which studied the application of long term home oxygen therapy, I view any potential reduction in service accessibility as a potential disaster. We have proven the efficiency and safety of home oxygen therapy. It adds quality years of life to over a million Americans."