Societies Join NAMDRC and CHEST on Regulatory Push; Respiratory Compromise Institute Announces Two Research Projects

NAMDRC and CHEST, along with the ATS and AARC, have submitted a series of recommendations to CMS to address an archaic, outdated Decision Memo from 2001 that stipulates that patients who receive home mechanical ventilation must have an artificial airway AND must succumb to death if the ventilator is removed. Even though the Decision Memo clearly signals that contractors have discretion in applying the rule, all the DME MACs have pushed forward with it in an attempt to control the growing use of noninvasive home mechanical ventilation, usually billed under HCPCS code E0464.

There are several moving pieces to this issue, and finding consensus was a challenge. While everyone agreed with the problems that have apparently triggered a review by the Office of the Inspector General, finding specific solutions to guide CMS took several months of collaborative work. Because CMS rejects all textbook definitions of mechanical ventilators, as well as FDA classifications, our approach was to explain that the presence of respiratory failure, by well accepted standards of care, includes use of a mechanical ventilator. Therefore, by defining “respiratory failure” and accepting the principle of mechanical ventilation as integral to treatment, a revised policy can now be created by CMS that reflects 2015 standards of care. Importantly, the societies also emphasized that chronic respiratory failure is not always a 24/7 medical phenomena; rather, it can occur nocturnally, intermittently, or progress into a 24/7 reality. In all of these examples, mechanical ventilation is warranted as long as respiratory failure is documented.

Tangential but integral to this issue is the barrier to bilevel devices, called respiratory-assist devices (RADs) by CMS. Because the rules for access to these devices are currently so problematic, physicians understandably make the shift to ordering NIV because that is the only option available for treatment for the patient. Therefore, integral to the recommendations related to home mechanical ventilation, the societies made a series of recommendations for improvement in RAD policies, as well. These recommendations are available on the NAMDRC website at www.namdrc.org.

Respiratory Compromise Institute: The Institute is currently pursuing two specific research endeavors, and the RFP for the large, meta-analysis is open for review at both the NAMDRC website www.namdrc.org and the Institute website, www.respiratorycompromise.org. The meta-analysis is a challenge because any literature search will reveal virtually nothing with the specific term “respiratory compromise” because of its newness. The challenge, therefore, is to conduct a broad search that encompasses all the key variables in the downward cascade from respiratory insufficiency to respiratory failure to respiratory arrest. That includes literature focusing on appropriate monitoring, treatment, therapies, outcomes, length of stay, etc. The Institute hopes to award the contract at the next meeting of its Clinical Advisory Committee, scheduled for March 1.

The second project focuses on Medicare data mining of hospital inpatient records. Beginning with a focus on records where respiratory failure is not present upon admission or within the first 24 hours following admission but present in the medical record, the data mining then expands outward to focus on the services provided, the length of stay, monitoring and therapies instituted, etc. A team of physician researchers are working with the data mining company to focus the research on specific ICD-9 codes (ICD-10 records will not appear in available data until late 2016/early 2017), CPT codes, and HCPCS codes. Hopefully, we will be able to begin with an initial 1 year snapshot, expanding to a multiyear longitudinal review to determine what trends, if any, exist. The data will then be sent to the physician researchers for analysis, and several papers will be generated as a result of those analyses.

NAMDRC Annual Meeting: The NAMDRC Annual Educational Conference is scheduled for March 3-5, 2016, in Palm Springs, California, at the Omni Rancho Las Palmas Resort. The entire program and registration information are available on the NAMDRC website. Registration for the conference is complimentary for new members who join NAMDRC after May 1, 2015, a value of $400. Physicians who want to take advantage of this special offer must contact the NAMDRC Executive Office at 703/752-4359.

NAMDRC and CHEST, along with the ATS and AARC, have submitted a series of recommendations to CMS to address an archaic, outdated Decision Memo from 2001 that stipulates that patients who receive home mechanical ventilation must have an artificial airway AND must succumb to death if the ventilator is removed. Even though the Decision Memo clearly signals that contractors have discretion in applying the rule, all the DME MACs have pushed forward with it in an attempt to control the growing use of noninvasive home mechanical ventilation, usually billed under HCPCS code E0464.

There are several moving pieces to this issue, and finding consensus was a challenge. While everyone agreed with the problems that have apparently triggered a review by the Office of the Inspector General, finding specific solutions to guide CMS took several months of collaborative work. Because CMS rejects all textbook definitions of mechanical ventilators, as well as FDA classifications, our approach was to explain that the presence of respiratory failure, by well accepted standards of care, includes use of a mechanical ventilator. Therefore, by defining “respiratory failure” and accepting the principle of mechanical ventilation as integral to treatment, a revised policy can now be created by CMS that reflects 2015 standards of care. Importantly, the societies also emphasized that chronic respiratory failure is not always a 24/7 medical phenomena; rather, it can occur nocturnally, intermittently, or progress into a 24/7 reality. In all of these examples, mechanical ventilation is warranted as long as respiratory failure is documented.

Tangential but integral to this issue is the barrier to bilevel devices, called respiratory-assist devices (RADs) by CMS. Because the rules for access to these devices are currently so problematic, physicians understandably make the shift to ordering NIV because that is the only option available for treatment for the patient. Therefore, integral to the recommendations related to home mechanical ventilation, the societies made a series of recommendations for improvement in RAD policies, as well. These recommendations are available on the NAMDRC website at www.namdrc.org.

Respiratory Compromise Institute: The Institute is currently pursuing two specific research endeavors, and the RFP for the large, meta-analysis is open for review at both the NAMDRC website www.namdrc.org and the Institute website, www.respiratorycompromise.org. The meta-analysis is a challenge because any literature search will reveal virtually nothing with the specific term “respiratory compromise” because of its newness. The challenge, therefore, is to conduct a broad search that encompasses all the key variables in the downward cascade from respiratory insufficiency to respiratory failure to respiratory arrest. That includes literature focusing on appropriate monitoring, treatment, therapies, outcomes, length of stay, etc. The Institute hopes to award the contract at the next meeting of its Clinical Advisory Committee, scheduled for March 1.

The second project focuses on Medicare data mining of hospital inpatient records. Beginning with a focus on records where respiratory failure is not present upon admission or within the first 24 hours following admission but present in the medical record, the data mining then expands outward to focus on the services provided, the length of stay, monitoring and therapies instituted, etc. A team of physician researchers are working with the data mining company to focus the research on specific ICD-9 codes (ICD-10 records will not appear in available data until late 2016/early 2017), CPT codes, and HCPCS codes. Hopefully, we will be able to begin with an initial 1 year snapshot, expanding to a multiyear longitudinal review to determine what trends, if any, exist. The data will then be sent to the physician researchers for analysis, and several papers will be generated as a result of those analyses.

NAMDRC Annual Meeting: The NAMDRC Annual Educational Conference is scheduled for March 3-5, 2016, in Palm Springs, California, at the Omni Rancho Las Palmas Resort. The entire program and registration information are available on the NAMDRC website. Registration for the conference is complimentary for new members who join NAMDRC after May 1, 2015, a value of $400. Physicians who want to take advantage of this special offer must contact the NAMDRC Executive Office at 703/752-4359.

NAMDRC and CHEST, along with the ATS and AARC, have submitted a series of recommendations to CMS to address an archaic, outdated Decision Memo from 2001 that stipulates that patients who receive home mechanical ventilation must have an artificial airway AND must succumb to death if the ventilator is removed. Even though the Decision Memo clearly signals that contractors have discretion in applying the rule, all the DME MACs have pushed forward with it in an attempt to control the growing use of noninvasive home mechanical ventilation, usually billed under HCPCS code E0464.

There are several moving pieces to this issue, and finding consensus was a challenge. While everyone agreed with the problems that have apparently triggered a review by the Office of the Inspector General, finding specific solutions to guide CMS took several months of collaborative work. Because CMS rejects all textbook definitions of mechanical ventilators, as well as FDA classifications, our approach was to explain that the presence of respiratory failure, by well accepted standards of care, includes use of a mechanical ventilator. Therefore, by defining “respiratory failure” and accepting the principle of mechanical ventilation as integral to treatment, a revised policy can now be created by CMS that reflects 2015 standards of care. Importantly, the societies also emphasized that chronic respiratory failure is not always a 24/7 medical phenomena; rather, it can occur nocturnally, intermittently, or progress into a 24/7 reality. In all of these examples, mechanical ventilation is warranted as long as respiratory failure is documented.

Tangential but integral to this issue is the barrier to bilevel devices, called respiratory-assist devices (RADs) by CMS. Because the rules for access to these devices are currently so problematic, physicians understandably make the shift to ordering NIV because that is the only option available for treatment for the patient. Therefore, integral to the recommendations related to home mechanical ventilation, the societies made a series of recommendations for improvement in RAD policies, as well. These recommendations are available on the NAMDRC website at www.namdrc.org.

Respiratory Compromise Institute: The Institute is currently pursuing two specific research endeavors, and the RFP for the large, meta-analysis is open for review at both the NAMDRC website www.namdrc.org and the Institute website, www.respiratorycompromise.org. The meta-analysis is a challenge because any literature search will reveal virtually nothing with the specific term “respiratory compromise” because of its newness. The challenge, therefore, is to conduct a broad search that encompasses all the key variables in the downward cascade from respiratory insufficiency to respiratory failure to respiratory arrest. That includes literature focusing on appropriate monitoring, treatment, therapies, outcomes, length of stay, etc. The Institute hopes to award the contract at the next meeting of its Clinical Advisory Committee, scheduled for March 1.

The second project focuses on Medicare data mining of hospital inpatient records. Beginning with a focus on records where respiratory failure is not present upon admission or within the first 24 hours following admission but present in the medical record, the data mining then expands outward to focus on the services provided, the length of stay, monitoring and therapies instituted, etc. A team of physician researchers are working with the data mining company to focus the research on specific ICD-9 codes (ICD-10 records will not appear in available data until late 2016/early 2017), CPT codes, and HCPCS codes. Hopefully, we will be able to begin with an initial 1 year snapshot, expanding to a multiyear longitudinal review to determine what trends, if any, exist. The data will then be sent to the physician researchers for analysis, and several papers will be generated as a result of those analyses.

NAMDRC Annual Meeting: The NAMDRC Annual Educational Conference is scheduled for March 3-5, 2016, in Palm Springs, California, at the Omni Rancho Las Palmas Resort. The entire program and registration information are available on the NAMDRC website. Registration for the conference is complimentary for new members who join NAMDRC after May 1, 2015, a value of $400. Physicians who want to take advantage of this special offer must contact the NAMDRC Executive Office at 703/752-4359.