The Ohio Deparment of Medicaid (ODM) has a directive under Ohio’s budget legislation effective 7/01/13 to unbundle certain services from the nursing home per diem rates and restore the payments to fee-for-service. OAMES actively worked to unbundle custom seating/wheelchairs since the change went into effect on 8/01/2009, along with the Multiple Sclerosis Society Ohio Chapters and Invacare, given the evidence that these services were virtually eliminated for nursing home residents.
In the 11th hour of the legislative process, oxygen and medical transportation services were also unbundled from the LTC per diems. OAMES did not support this decision for oxygen, nevertheless, the Ohio Department of Medicaid by law is required to unbundle and update the oxygen rules and fees to operationalize the mandate for effective date of 1/01/14.
In a meeting with Medicaid officials on September 26, ODM informed OAMES that they would restore the private residence and long term care oxygen rules into one policy and reduce the oxygen rates for both LTC and homecare to 64% of the lowest Round 2 bidding rates! (For example, E1390 would drop from $153.64 to $54.89.)
OAMES representatives expressed strong and immediate opposition and agreed to meet on October 11 at an HME providers’ facility to educate the Medicaid policy staff and decision-makers on the various modalities and technology of the oxygen benefit, discuss the unique differences of the Medicare and Medicaid populations and how these changes would devastate Ohio Medicaid consumers who rely on home oxygen services.
The Oct. 11 meeting was lengthy and constructive. Thank you to Carl Mulberry and his team at Columbus Medical Equipment for hosting an excellent site visit and in-service. At this meeting, OAMES provided a response paper which supplemented our discussion about the evolution of the oxygen benefit, the cross subsidization of codes, patient acuity and consumption needs, and raised the need to reduce administrative burdens and processes that increase not only providers’ costs, but the State’s expenses as well.
The rules “package” to operationalize unbundling was filed on October 15 to meet the January 1 implementation date and the public hearing has been scheduled for Nov. 18. ODM asked OAMES to submit revisions to the proposed oxygen rule now which we are currently doing. In the meantime, we need ALL OAMES member companies who provide oxygen service to PARTICIPATE in the public process and make your concerns heard!
How to access proposed rules:
Action needed by OAMES members:
1.Submit comments and attend the public hearing!
You can send your comments as noted below or present them at the hearing. Even if you’d prefer not to read your comments at the hearing, submit them by email but attend so that we can fill up the room to show the strong opposition for these rules. (Be sure to copy me at kam@oames.org when you submit your comments.)
Hearing: November 18, 2013, Monday – 10:00 a.m.
Lobby Hearing Room, Rhodes State Office Tower
30 East Broad Street, Columbus, OH 43215
Mail: Ohio Department of Medicaid
c/o Ohio Department of Job and Family Services
Office of Legal and Acquisition Services
30 East Broad Street, 31st Floor, Columbus, OH 43215-3414
Fax: (614) 752-8298
Email: rules@jfs.ohio.gov
2. Reach out to your referral sources, respiratory therapists in your community and affected consumers and urge everyone to engage. These proposed rate changes will absolutely compromise patient care and devastate the home oxygen benefit!
3. Attend OAMES Annual Meeting on Nov. 19-20 to hear Director John McCarthy’s update and share your concerns in-person. He is scheduled to make a Medicaid presentation on day one which presents a timely opportunity to voice concerns with the top Medicaid official. Representatives from Medicaid Policy will also be hosting a session so this is an excellent time to get in front of these decision-makers.
If you have any questions or would like more information, please contact OAMES executive director Kam Yuricich at OAMES. We understand these battles are exhausting and frustrating but it’s essential to engage in these efforts for a healthcare benefit that relies heavily on government payers.