I know it might sound overly dramatic, but yesterday may have been one of the most important in the evolution of the Rehabilitation Technology Supplier industry within the State of Texas.
For those of you who are not aware, yesterday The Texas Department of Health and Human Services (HHSC) conducted the first of a series of public rate review hearings regarding the reimbursement rates applicable within the Texas Medicaid Program. While HHSC had announced several hearings to be held yesterday, the one of particular interest to rehab providers was the hearing relating to the proposed rate changes to a substantial number of E codes. E codes are of course the codes under which most mobility and seated positioning products are provided. In its announcement, HHSC had proposed to re-price many of the E code reimbursement fees to an amount equal to, or in many cases, a fraction of the current Medicare reimbursement rates for the same codes.
The result of the proposed rate change, if ultimately implemented, would be to dramatically reduce the reimbursement available for a large spectrum of pediatric mobility and seated positioning equipment. The reduction would be of such substance as to simply make it economically impractical for providers to deliver many of the pieces of equipment regularly provided to the pediatric patient base of Texas Medicaid.
With pretty short notice, the leadership of the Greater Texas Rehab Providers Council (TXRPC) assembled a task force of providers to compile data and analysis on the proposed rate changes. They then rallied a sizable group (I am estimating 30 – 40 providers) to attend and testify at the formal hearing in opposition to the proposed changes. This was in and of itself a testament to the maturation of the industry as the group was able to hit the task running. While the response, organization, and content was impressive the real reason I believe the industry had a good day is that for the first time that I am aware of the industry was able to clearly and effectively articulate to HHSC rate and policy staff (there were a sizable number in attendance which is not normal) that using the Medicare reimbursement rates as the benchmark for establishing Medicaid rates on mobility and seated positioning equipment is at its core flawed.
The industry presented an organized, professional, and concise detailing that simply applying the Medicare Established allowable to a code and using it as the applicable Medicaid allowable would serve to totally dismiss the following factors:
- Medicaid and Medicare serve very different demographic bases, and
- A Medicare allowable is generally based upon factors relative to a far less complex and less costly product universe than is typically utilized within the Medicaid program, and
- Medicaid presents dramatically different cost factors in its prescribed distribution model than are applicable in the Medicare program model.
What the ultimate result of the hearing will be is yet unknown. If they were listening (I believe all indications pointed to they were) we may for the first time have opened a door of understanding which could provide the foundation for a major shift in how reimbursement rates are established in the Texas Medicaid Program for mobility and seated positioning equipment. I’d say that makes it a good day.