CMS Proposed Updates to Home Infusion Benefit Still Discount Role of Digital Health

| Brittany McCullough
An infographic about telehealth in action

A couple of months ago, CMS proposed updates to the home health prospective payment system and finalized the implementation of the permanent home infusion therapy benefit. According to the accompanying fact sheet, this proposed rulemaking further promotes the use of telecommunications technology in Medicare in addition to making regular payment rate updates for calendar year (CY) 2021.

Most notably, if finalized as written, this proposal would allow for the use of telehealth and related technology as part of the home health benefit beyond the existing public health emergency (PHE) related to COVID-19. This use of technology would have to be related to the services being provided, appropriately accounted for in the plan of care and tied to specific goals with the intent of improving patient outcomes. While this provision is encouraging, I do want to be clear that this does not mean that telehealth services rendered under the home health benefit will be reimbursed more than they are now. CMS very clearly states that statutory restrictions “[prohibit] payment for services furnished via a telecommunications system if such services substitute for in-person home health services ordered as part of a plan of care.” As such, CMS is proposing to make a change within their regulatory authority which is to permanently finalize the amendment to 42 CFR §409.43 as promulgated under the first COVID-19 PHE interim final rule (IFC) that was published back in April.

Additionally, CMS proposed implementing a number of enrollment policy changes in accordance with the finalization of the permanent home infusion therapy benefit for CY 2021. As part of this, CMS reiterated that home infusion therapy suppliers must be accredited in order to enroll in Medicare. The agency also continues to reiterate that payment to qualified suppliers is for an “infusion drug administration calendar day in the individual’s home, which, in accordance with [the Social Security] Act, refers to payment only for the date on which professional services were furnished to administer such drugs to such individual.” URAC believes this is inadvertently limiting because it does not appropriately account for the ongoing patient education and monitoring that occurs on days in which a drug is not administered in the home. Furthermore, this definition continues to discount the use of remote patient monitoring (RPM) and other technology that can be leveraged when a patient is self-administering infusible drugs under the guidance of a remote health care provider.

To read URAC’s comments to CMS-1730-P in full, click here.

To learn more about URAC’s deemed Medicare Home Infusion Therapy Supplier Accreditation, click here.


Brittany McCullough photo

Brittany McCullough, Manager, Health Policy and Government Programs.

Brittany McCullough, URAC's Manager of Health Policy and Government Programs, tracks and analyzes legislation and regulations of importance to URAC stakeholders. She also helps manage URAC’s public policy external affairs portfolio and oversees compliance with government deemed programs. Most of her policy and research work has been related to the ACA, Medicaid managed care, Part D, telehealth and mental health parity. She holds a B.S. in Neuroscience and a Master of Health Administration.

Views, thoughts and opinions expressed in my articles belong solely to me, and not necessarily to my employer.

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