April 9,1999

Health Care Financing Administration
Office of Information Services,
Security and Standards Group
Division of HCFA
Enterprise Standards
Attention: Louis Blank
Room N2-14-267500
Security Boulevard
Baltimore, Maryland 21244-1850

Dear Mr. Blank:

The American Association for Respiratory Care, a 37,000 member professional association of respiratory therapists strongly supports HCFA's undertaking a study on the effect that the BBA provisions reducing home oxygen reimbursement has had on the access of Medicare beneficiaries to the home oxygen therapy portion of the DME benefit.

The AARC strongly recommends that the study include in its focus the effect of the oxygen therapy fee schedule reductions on DME suppliers' ability to provide oxygen therapy services, which includes utilizing respiratory therapists, along with the oxygen therapy equipment.

While not reimbursed separately for the respiratory therapist professional component, the majority on DME suppliers providing home oxygen therapy, have also provided the Medicare beneficiary with the services of a respiratory therapist. Respiratory therapists are utilized to assure that patients requiring home oxygen, not only receive the proper instructions for the set-up, use and maintenance of the equipment, but also receive the critical clinical assessment.

The AARC believes that because of the reduced reimbursement in the home oxygen fee schedule, many DME suppliers can no longer afford to provide the services of respiratory therapists to the Medicare beneficiary. We believe this is a key change caused by the BBA provisions. We strongly urge that any study undertaken by HCFA must collect data on this critical quality of care issue.

Sincerely,

Cheryl A. West, MHA
Director, Government Affairs