Oxygen cap

Please reference the “Selective Contracting” comments just submitted. Specific to this cap I will just say that there is a false assumption that we have been paid well enough in three years that we can write blank checks in the final two years. Providers have been paring back services to some extent while doing everything we can to protect beneficiaries since the BBA cuts in 1993. To compare the acquisition cost of a concentrator on the internet to what a provider potentially could be reimbursed for stationary oxygen over a five year period is an apple to giraffe comparison. First, it exaggerates what providers were actually paid by using hypothetical numbers and second it ignores the value of the service element. The equipment cost represents at most 28% of what we do for an oxygen patient. If CMS really wants to ignore the infrastructure that exists preventing unneeded 911 calls and just tell the beneficiaries to shop on line for their concentrator (to be drop shipped to them) we have got to make some changes at CMS. The comparison also ignores the cost of providing portable oxygen which is grossly underpaid. For CMS to then setup a totally unreasonable and unrealistic set of rules that do nothing but say, “we’re not paying so you have to” only reveals how far CMS is from understanding the value we bring. Paying for patients that move outside of our service area? We are threatened with losing our Medicare license if we don’t pay another provider in another state who is licensed in that state to provide oxygen to “our” patient after they permanently move there. That is incredible. Please, let’s start over. Pay something close to the value we provide so long as the patient needs it. At this point I support the oxygen reform so we can at least get on the same page regarding what CMS pays for and intends to be part of the Medicare benefit.

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