NHF advocates for specific issues concerning Medicare that would affect access to care for people with bleeding disorders.
Skilled Nursing Facilities
Medicare reimbursement for skilled nursing facilities (SNFs) limits access to these facilities for patients with hemophilia and other severe bleeding disorders following an inpatient hospital admission.
SNFs are paid a prospectively determined daily rate for all SNF services provided to patients covered under a Medicare Part A stay. This bundled payment includes nursing and therapy components (adjusted by case mix), drugs, supplies and equipment, in addition to a room/board and administration component. This payment is expected to cover all operating and capital costs of SNF facilities.
It is extremely difficult to find a SNF that will care for hemophilia patients due to the significant losses the SNF will incur as a result of clotting factor costs. Costs for a person with hemophilia will far exceed the per diem payment rate for the highest level SNF stay.
If a SNF is unavailable, other options for patients include inpatient rehabilitation facilities (but many patients are not strong or healthy enough to meet admission and/or treatment requirements), keeping the patient in the acute inpatient setting longer than needed, or sending the patient home. None of these options allow for the level of coordinated, skilled care necessary for a successful recovery.
The Medicare SNF statute allows for certain costly, highly specialized services that SNFs do not typically provide to be billed separately under Medicare Part B. Services that can be billed separately include chemotherapy, radioisotopes, certain types of prosthetics and EPO for dialysis patients.
NHF seeks to add clotting factor therapies to the list of services that can be billed separately under Medicare Part B for patients with hemophilia during a SNF stay. The provision of clotting factor to patients is comparable to the above-referenced specialized services where Medicare recognizes the need for separate treatment.
S. 3233, the Hemophilia SNF Access Act, was introduced by Sen. Menendez (D-NJ) on January 28, 2020 and has three cosponsors. The bill would add clotting factor to the list of therapies carved out of the SNF bundled payment that could be billed separately fee-for-service.
The House companion bill, H.R. 5952, was introduced by Rep. LaHood (R-IL) February 5, 2020 and has twelve cosponsors.