The U.S. Office of Inspector General (OIG) recently conducted a review of $1.1 billion in Medicare-allowed charges for about one million monthly noninvasive ventilator rental units billed under the Healthcare Common Procedural Coding System (HCPCS) code E0466 from 2016 to 2018.

In its September 2020 report, the OIG indicated that Medicare-allowed charges for noninvasive ventilators increased from $279.9 million for 280,533 monthly rental units in 2016 to $424.4 million for 417,335 monthly rental units in 2018, an increase of 52 percent. The OIG estimated that Medicare and beneficiaries could have saved $86.6 million if Medicare-allowed charges were comparable with payment rates of select non-Medicare payers on HCPCS code E0466. Of this payment difference, the OIG estimated that Medicare paid $69.3 million, and Medicare beneficiaries paid $17.3 million. The OIG recommends that CMS review Medicare-allowed charges for noninvasive ventilators and add HCPCS code E0466 to the competitive bidding program as soon as practicable.

According to the OIG, ventilators are machines that supply oxygen, or a mixture of oxygen and air, and that are used in artificial respiration to control or assist breathing. Noninvasive ventilators are ventilators in which the interface, such as a mask or chest shell, does not enter the body.

CMS has since confirmed that it had been evaluating noninvasive ventilators for potential inclusion in the competitive bidding program. CMS also confirmed that noninvasive ventilators initially had been included in Round 2021 of the program. However, the product category was removed on April 9, 2020, because of the COVID-19 pandemic, limited access to ventilators, and other factors.

CMS will consider whether to include noninvasive ventilators in future rounds of the program. The AASM previously submitted comments on a Competitive Bidding program proposal.

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