Oh 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.