Will New HBOT centers get Medicare reimbursement if this happens?

DRAFT-LCDOh boy! They did it again! If you have been asleep (like I have) or simply blinked – I think it’s time to wake up and smell the “regulations”.  Yes, the regulations, I said it.  You are now regulated from the minute you wake up till the second you go to bed (and even when you sleep), and the part that will affect all of us that you may want to familiarize yourself with is NOW here -UHMS ACCREDITATION.   I thought that if I ignored the subject that it would just wither and die but it didn’t -so here we are.  Novitas (a Medicare middleman or as aptly named MAC) -that is “Medicare Administrative Contractor” has now come up with new items on their menu that they would like to FORCE down your throats in respect to the payment for hyperbaric oxygen therapy.

They (Novitas) have drafted an LCD (surely with the help of the UHMS) that will require ALL hyperbaric centers that bill Medicare and/or see Medicare patients be “UHMS ACCREDITED” prior to being reimbursed for the HBO treatments.

It says Specifically: “IT IS REQUIRED THAT FACILITIES RECEIVE AN ACCREDITATION SURVEY BY THE UNDERSEA & HYPERBARIC MEDICAL SOCIETY”  What if you receive an accreditation survey and do not pass? Nothing here states that you must pass in order to get reimbursed right?  Would proof of a check to the UHMS be good enough to “prove” you “received an accreditation survey?”  Hmmmm…..moving on.

What kills the above statement is from the UHMS accreditation guidelines itself:  “A clinical hyperbaric facility is eligible for
an accreditation survey by the Undersea & Hyperbaric Medical Society if it: 1. has been providing hyperbaric treatment services for at least one year before applying for an on-site survey”

Although surely the “intent” is to ensure that all hyperbaric facilities are providing safe, effective, efficacious, and high quality therapy to their patients, the unintended consequences may outweigh its original intent.  Let’s hypothesize for a second – If  “facility A”  in a hospital opens its doors to start treating Medicare patients with HBOT but is required to have its doors open for a minimum of one year prior to receiving UHMS Accreditation (as defined in page 6 of the UHMS Accreditation Guidelines) – who wins?  Does this present a Catch 22?  Surely some brainiacs out there have thought this over.  Does this, and will this minimize the growth of hyperbaric facilities?  Is this the actual intent?  After all the UHMS will be making a killing at around $5000 per facility that they accredit (if just 400 hospitals are required to get accredited the UHMS stands to make at least $2 mil).  Who else wins?  Novitas and CMS of course.  They wouldn’t have to reimburse newer hyperbaric facilities for at least 1 year – but then again, who in the right mind would open a facility if they knew that a majority of the treatments wouldn’t be covered/paid for?

Clearly from just the examples above we have far more questions generated than answers, and as a former LA Council Official I would vote to table this draft until someone “clearly” defines how it would affect a whole industry and not just one entity.  What now?  Well we all wait and hope that the BOHICA moment is delayed for some better regulation that is more sensible and economically viable for all hyperbaric facilities.   In the meantime, you may as well start getting prepared because as you know -ANYTHING CAN HAPPEN.

NOVITAS DRAFT LCD

UHMS ACCREDITATION MANUAL

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One thought on “Will New HBOT centers get Medicare reimbursement if this happens?

  1. This LCD revision is only a proposed draft and hasn’t gone into effect yet…and I have doubts as to if it will gain much traction. I personally flew to Dallas last month and spoke on this proposed draft and there are many issues with it for both the hospital and free standing center alike. For starters, what authoriative power does the UHMS really have to do this? Who put them in charge? Why are they the only ones who can accredit? There are organizations other than Joint Commision who can survey a hospital, so why does the same not apply for HBOT? For anyone who has been through a UHMS accredidation you know 1st hand it has several issues in of itself, plus not to mention that the UHMS has a limited # of surveyors. The burden is placed on the UHMS to show that they can handle the capacity to accredidate all the centers that apply in a timely fashion and currently I don’t believe that to be the case. Secondly, the cost needs to be justified for the survey and not to mention that CMS has already admitted that the reimbursement of a freestanding center vs a hospital based has a deficit of 75% towards the free standing center. Physicians in hospitals receive the 99183 for the supervision of HBOT (as do free standing centers), yet it is only the hospital that can bill out the facility charge of C1300 (typically a x4 charge) for each treatment whereas the freestanding center can not. Why? I’ll tell you why…because it is assumed that the hospital has ICU and/or ACLS trained staff within the hospital. Again…why is this a requirement? Unless it is a critical care patient, I’d venture to guess that over 97% of hospital and freestanding HBOT patients are treated on a M-F basis and generally as outpatients who drive themselves or arrive via ambulance from a nursing facility. Read Novitas’s current LCD that is in effect…..the requirements for a freestanding center significantly outweigh those of the hospital. ACLS staff chamber side, the physician must have at least 300 logged dives under his/her belt….hospitals do not require either of these because it is “assumed” that the hospital has a ICU and/or ACLS trained staff on site. So what? They don’t determine what to do in the event of a HBOT emergency…the HBOT physician does. I can not tell you how many times I’ve seen hospitals realize what a “cash cow” a HBOT unit would be and they grab a physician who’s most likely never even seen a chamber and send him/her out to take a 40 hr course and now one week later he or she is all of a sudden the resident “expert” of HBOT medicine and immediately allowed to supervise dives and bill out for the 99183 while the hospital bills out for the C1300 x4. HOW INSANE IS THIS?!?!?! By comparision, the free standing center is a far safer, better credentialed and licenced center to receive HBOT than a hospital. Please understand, I’m not against the UHMS, Novitas or CMS….what I am against is the unfair practice of reimbursement, the extremely unfair practice of freestanding centers requiring more credentials, certifications and experience vs a hospital based center, yet the hospital receives 75% more in reimbursement. How is a free standing center supposed to pay for rent, supplies, O2, staff, utilities, and all other overhead when they are basically not receiving reimbursement for the facility charge? I firmly believe that there needs to be some type of authority having jurisdiction over HBOT centers aside from the NFPA and PVHO that is able to walk onto any center, hospital or free standing, and have the ability and power to arrive unannounced and verify everything is safe and kosher. The UHMS deserves all the credit in the world for their unparalled efforts in bringing legitimacy and awareness of HBOT into mainstream medicine……but yet they answer to themselves and therefore no system of checks and balances exists which is a recipe for corruption and private agendas. The “in fighting” within the industry needs to stop as it has become more like a grade school playground than professionals who are striving to deliver the best possible quality of care to the patients they serve. Until this happens, it will continue to be “tug-of-war” with the patients being the ones who ultimately get the short end of the stick.

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