AAHomecare Cites Flaws in OIG Report on Inhalation Drug Therapy, USA

Main Category: Caregivers / Homecare
Article Date: 09 Oct 2005 - 0:00 PDT

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AAHomecare noted serious flaws in the Health and Human Services Office of Inspector General (OIG) report, released last week, that grossly understates the service components of home inhalation drug therapy. The OIG report, "Review of Services Provided by Inhalation Drug Suppliers," fails to include the core services for dispensing such drugs. For example, the OIG did not include: pharmacy related work needed to fill an order, order processing, packaging and shipping, delivery, billing and coding, quality control, as well as administrative and overhead costs. Thus, the OIG report is of limited value in determining the appropriate level for the Medicare dispensing fee.

While these core services were not included in the OIG study, they constitute most of the cost of dispensing inhalation drugs, as illustrated by the October 2004 Government Accountability Office (GAO) Study, "Appropriate Dispensing Fee Needed for Suppliers of Inhalation Therapy Drugs," (p. 9). The GAO collected cost data on various inhalation dispensing fee services, and the core services above accounted for about 85 percent of the cost of the total services rendered. It is not surprising that the OIG concludes that only a limited number of services were provided when they captured only about 15 percent of those services and related costs in their survey instrument.

In addition, the OIG study was hampered because the OIG conducted a paper review only. The OIG did no field work such as interviews and on-site visits. The flaw in a paper review is that many of the services they examined are not required to be documented - for example, ongoing patient education. But the OIG excluded any service for which there was not specific documentation.

Finally, the OIG's survey instrument was flawed. First, it did not state that documentation was required in order for a service to be counted. More importantly, the survey instrument asked for information on only 11 poorly defined services. If the OIG had taken more care to compile a complete list of services (as in the survey by Muse and Associates), the responses would have been more extensive and complete.

The OIG greatly overstates its conclusions about a general lack of dispensing fee related services primarily because it excluded from its study the core services of providing inhalation drug therapies, as well as billing and administrative costs. Since the OIG studied only a small fraction of the costs of dispensing such drugs, it is of limited value in determining future dispensing fee levels.

CMS Open Door Forum October 20
The next CMS Home Health, Hospice & DME Open Door Forum is scheduled for October 20, 2005, 2:00 p.m. ET. Call 800-837-1935 and use conference ID 2865480.

Still Time to Register for Medtrade and AAHomecare Continuum of Care Conference
There is still time to register for AAHomecare's Continuum of Care Conference, October 17, and Medtrade, October 18-20. For registration information, visit: aahomecare.org/cde.cfm?event=101963.

American Association for Homecare
http://www.aahomecare.org

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