5 Things you need to know about the HIT services benefit & HIT supplier requirements
The home infusion therapy (HIT) benefit was initially created in 2016 when the 21st Century Cures Act was enacted into law. Amendments in the Act established the Medicare HIT benefit for coverage of home infusion, therapy-associated professional services for certain Medicare Part B drugs and biologicals. Then in 2018, the Balanced Budget Act provided for a transition period in which home health agencies (HHAs) could continue to provide the professional services related to part B infusion drug therapy in the home until the HIT benefit would be fully carved out of the home health Part A benefit. The transitional requirements through implementation requirements were then finalized in phases across the last three home health final rules.
The HIT services benefit became effective January 1, 2021, and has proven to be a source of confusion for many HHAs, particularly as it relates to understanding how benefits and services interact and can be fragmented across multiple providers. Also, for HHAs that continue to provide the professional services needed to administer covered Part B drugs in the home, there needs to be a determination as to whether the agency will contract with a qualified HIT supplier to provide the professional services or become accredited and enroll as a Medicare part B HIT supplier and directly bill Medicare Part B for the professional services. Before you decide whether becoming a HIT supplier is the right move for your agency, it’s important to have a strong understanding of the benefit itself, as well as the requirements for becoming a HIT supplier.
Here, we discuss five things you need to know about the HIT services benefit and the HIT supplier requirements:
5 Things you need to know about the HIT services benefit.
Coverage is split between the Part B HIT services benefit and the Part B DME benefit.
The HIT Services benefit is a new Medicare Part B benefit. And while it provides coverage for the professional services associated with a certain subset of Medicare Part B DME infused drugs that are covered under the external infusion pump LCD, the drugs and related infusion supplies are separate and covered under the Part B DME benefit. Here’s a breakdown of the coverage differences:
The DME benefit covers (provided by DME supplier): – External infusion pump, delivery/setup – Related supplies/pharmacy services – Infusion drug
The HIT services benefit covers (provided by HIT supplier): –Professional services (i.e., nursing) –Training and education (not otherwise covered under the DME benefit) –Monitoring furnished by a qualified HIT supplier that’s needed to administer infusion drug in patient’s home (24/7 availability)
Only a subset of Part B DME infused drugs are covered under the external infusion pump LCD.
While enteral or parental nutrition, IV immune globulins (IGs), or any Part D infused drugs are not covered, drugs that are covered under HIT professional services are grouped into three payment categories:
– Category 1: includes antifungals and antivirals (antibiotics are not included), inotropes, pulmonary hypertension drugs, some select pain management drugs, and chelation therapy – Category 2: includes subcutaneous therapy (subcutaneous IGs) – Category 3: includes chemotherapy
The professional services covered under the HIT benefit include nursing care and in-home professional services such as:
Training and education on care and maintenance of vascular access devices (VAD): includes services such as hygiene education, VAD care and troubleshooting instruction, infection control education, and site care/dressing changes.
Patient assessment and evaluation: includes services such as patient assessments and vitals, evaluation of caregiver support, assessment of any adverse effects or infusion complications, comprehensive medication review and reconciliation, and blood collection for labs.
Medication and disease management education: includes services such as instruction on disease management and self-monitoring, lifestyle and nutrition modification, education on drug mechanism of action, potential side effects, drug interactions, adverse and infusion-related reactions, drug therapy goals, and education on household/contact precautions, as applicable.
Remote monitoring/monitoring services: includes services such as communicating with patients and caregivers regarding changes in condition or treatment plans, monitoring patient response to therapy, and assessing compliance.
These professional services covered under the HIT benefit are distinct and separate from those paid under the DME benefit and are bundled into the payment amount for the professional services visit.
Payment for HIT services includes a single unit for each infusion drug administration calendar day in the beneficiary’s home.
Payment for HIT services includes a single unit of payment for each infusion drug administration calendar day in the beneficiary’s home.
A HIT supplier can only bill for professional services visits for the days on which home infusion therapy services are furnished by a skilled professional in the beneficiary’s home, on the day of the infusion drug administration. The initial visit has a higher payment than subsequent visits.
Providing and billing visits under the HIT benefit requires coordination with the DME supplier.
Although, as of January 1, 2021, a HIT supplier can bill for the professional services HIT visits, payment is dependent upon a covered infusion drug/service being billed and approved for payment by the DME supplier. Coordination between the two suppliers is very important—not only from a care coordination perspective, but also from a sequential billing perspective—as the HIT supplier’s claim will be denied if the DME has not yet billed the first drug/service, establishing the beneficiary in Medicare’s common working file (CWF).
Even though the two suppliers bill through different Medicare Administrative Contractors (MACs), there is an edit in the CWF to match up the claims. Because the HIT professional services are contingent upon a home infusion drug being billed, the drug associated with the HIT professional services visit must be either billed with the visit or no more than 30 days before the visit. If a matching DME claim is not found, the HIT professional services claim will be denied.
5 Things you need to know about HIT supplier requirements.
A home health agency can become a qualified HIT supplier.
A qualified HIT supplier can be a pharmacy, physician, or other provider or supplier licensed by the state in which they furnish items and services, and this includes home health agencies.
HIT suppliers must provide seven-day-a-week/24-hour service coverage.
HIT suppliers must furnish infusion therapy to individuals with acute or chronic conditions requiring the administration of home infusion drugs. They must ensure the safe and effective provision and administration of home infusion therapy on a seven-day-a-week, 24-hour-a-day basis.
HIT suppliers must be accredited by an Accrediting Organization (AO) approved by the Centers for Medicare and Medicaid Services (CMS).
A prerequisite requirement for enrolling in Medicare Part B as a HIT supplier is attaining accreditation for home infusion therapy by a CMS-approved AO. The good news is that all three home health AOs are also CMS-approved AOs for home infusion therapy.
The survey and quality oversight for the HIT services benefit will be administered by the AOs, who are responsible for establishing and overseeing all quality standards.
HIT suppliers must be enrolled in Medicare Part B.
To enroll, providers must submit Form CMS-855B, pay the application fee, and comply with screening requirements based on assigned provider risk. This is a limited risk level category for screening that contains the same appeal rights for enrollments, denials, and revocations.
HIT suppliers may subcontract for professional services.
HIT suppliers can subcontract for and bill the professional services in addition to providing the professional services directly—meaning you could choose to forego becoming a HIT supplier and subcontract with a HIT supplier to provide the professional HIT services.
With complex, fragmented coverage requirements and opportunities to become a HIT supplier or subcontract to provide professional services, you should take the time to assess your current operations and evaluate your options carefully. Stay tuned on our blog for whether becoming a HIT supplier is the right move for your home health agency. We’ll also assess operational considerations to help inform your decision-making.