AOA pushes hard to address increased cost for necessary personal protective equipment

The optometric practice of Steven Eiss, O.D., always considered patient safety a priority. But in the era of COVID-19, patient safety has gone to new heights.

Dr. Eiss, who practices in Pennsylvania and chairs the AOA's Third Party Center Executive Committee, rattles off a list of "new normal" personal protective equipment, known as PPE: masks, face shields, goggles, gloves, clothing protection or scrubs.

And that's not the half of it.

Dr. Eiss' list grows as he mentions sneeze barriers for the reception areas, disinfectant sprays and cleaners, and frame-sanitizing units to disinfect frames that patients have handled.

"Most of these are items that most practices didn't utilize on a regular basis prior to COVID-19 and didn't have an excessive supply on hand," he says. "Masks and face shields are something that most doctors of optometry would only use with a patient with symptoms of contagious illness. Honestly, this is something that I almost never had to utilize in my 20-plus years of practicing. These items are probably what has become the most difficult to obtain, and we were least likely to have a supply on hand prior to this pandemic, and now it's in demand across all of health care.

"Gloves are something most of us already had in practice, but we are now likely to use them with a higher percentage of patients, not just those that we are worried about direct contamination," he adds. "My practice already utilized lab coats or scrubs for the practitioners and staff. There has definitely been an increased migration to this by many practices and the cleaning/sanitizing of these is a bigger issue."

Patient safety remains highest priority but comes at a price.

Recognizing this bigger, unprecedented burden on optometry practices, the AOA is pushing on multiple fronts to offset the financial blow.

In its unflagging effort to support doctors of optometry providing essential care amid this pandemic, the AOA is seeking greater relief for practices needing PPE to ensure the safety of patients, doctors and staff.

"The AOA has been fighting nonstop through this crisis to ensure that doctors of optometry have the resources we need, tackling the obstacles as they appear," AOA President Barbara L. Horn, O.D., says. "As one of the professions at the highest risk to contract this virus and most negatively impacted financially, it is paramount that our government and plans recognize the burden we face and provide relief and adequate reimbursement."

Urging CMS to reevaluate reimbursement

While praising the Centers for Medicare and Medicaid Services (CMS) in a May 14 letter for its decision to give ordering authority for COVID-19 testing and payment for specimen collection to doctors of optometry, the AOA underscored that the specimen collection requires additional PPE not now covered. The original valuation of the service (CPT 99211) does not account for these additional complex factors, the AOA argues, in urging CMS to reevaluate the coding and properly reimburse for the physician service.

"While expanding access and reimbursement for this type of specimen collection is a positive step toward ensuring greater testing for COVID-19, we are concerned that the reimbursement is limited," Dr. Horn says in her letter to Seema Verma, CMS administrator. "CMS has indicated that CPT code 99211 will be used to report specimen collection in a physician's or qualified non-physician practitioner's office and that the payment rate will be $23.46.

"This type of specimen collection will require additional personal protective equipment (PPE) to ensure safety of the patient, the physician and the staff," she writes. "We do not believe that the original valuation of CPT 99211 accounts for these additional complex factors. We urge CMS to reevaluate the coding and reimbursement for this important physician service and appropriately reimburse physicians.

The AOA also asked CMS to consider:

• Adjusting reimbursement models for the duration of the crisis to compensate doctors for PPE, based on costs for PPE or for payment of the code 99070 to account for PPE costs. "CMS should revalue the resources required to provide care or recognize this added expense," Dr. Horn writes.
• Delaying the implementation of the completion of Qualified Clinical Data Registry (QCDR) measure testing policy by a year, given the consequences of the pandemic on practices.

Dr. Horn notes in the letter that not only does the increased demand for PPE make it harder to secure, but also has raised costs. She cites a report by the Society for Healthcare Organization Procurement Professionals, which showed the cost of many PPE items increased more than 1,000% since the COVID-19 outbreak.

"The necessary use of PPE for patient care will significantly increase the cost to the provider of each patient encounter," Dr. Horn says in the letter. "This increased cost for providers is not reflected in the reimbursement amounts from insurance plans. We urge CMS to consider its ability to help offset the financial burden of PPE for Medicare providers."

Compelling plans to increase payment for services

Letters have gone out to the top 50 health insurance plans and 16 vision plans seeking relief for doctors of optometry.

Again arguing that reimbursements did not reflect the true costs of providing care, AOA requested the plans take one of two actions: pay an add-on, per-patient surcharge to cover the costs of PPE (billed by using CPT code 99070) or implement a per-patient encounter increased payment for services that require additional supplies and time. The options would better reflect the increased cost of each patient encounter due to the need for PPE and other supplies, the AOA says. Either option would better reflect the costs incurred at patient visits.

"When adjudicating claims, the AOA believes that it is inappropriate for any third party payer, vision plan or health plan to unfairly place the cost burden on doctors of optometry or patients by disallowing or bundling charges for PPE and COVID-19 prevention supplies on the pretext that such expenses were already calculated or included in the payment for any service or procedure billed during the visit," Dr. Horn says in the letter. "Taking no action to account for these significant costs is, in effect, an automatic reduction in coverage.

"The higher cost of care also threatens to reduce patient access to care far beyond the reduced availability of appointments," she says. "When patients cannot safely get eye health and vision care from doctors of optometry, they will turn to more expensive and riskier settings, such as local emergency departments. Our members report that 60% of the patients they treated for urgent and emergency care during the pandemic would have otherwise sought care at urgent or emergency care settings. Therefore, increasing reimbursement per patient or per service could be offset by the savings for patients not needing to go to the emergency department."

Working on Capitol Hill for relief

The AOA also is continuing its work on Capitol Hill to ensure lawmakers understand and continue to respond to the needs of doctors of optometry and other physicians, including those facing mounting costs of retrofitting practices to comply with new patient safety protocols and of procuring and resupplying PPE.

In a May 20 letter to U.S. House and Senate leaders, the AOA outlined priorities for further federal pandemic response legislation, which is now being assembled on Capitol Hill. Among optometry's top priorities, the AOA urged lawmakers to provide direct support for optometrists and other physicians facing new and daunting PPE and office safety costs.

"With measured moves toward again providing close-contact eye and vision care, doctors are already facing substantial costs associated with retrofitting offices to comply with new patient safety guidelines and for the purchase and frequent use of PPE," Dr. Horn says. "AOA supports efforts in Congress to better direct PPE resources to doctors of optometry and other front-line physicians, including through direct distribution, federal support for procurement and restocking, and tax incentives to help offset retrofitting and ongoing PPE costs."

Doctors can learn more and help build support for AOA's top priorities through the AOA's Online Legislative Action Center or by texting "AOA" to 855.465.5124.

Stay informed with the AOA's COVID-19 guidance and resources

AOA members can connect with vendors through AOAExcel^®'s group purchasing organization (GPO) for long-term access to hospital-grade, quality-controlled PPE at competitive pricing.

The AOA continues to closely monitor all developments in the U.S. public health response to COVID-19, as well as institute an all-out mobilization on behalf of the profession that includes not only 24/7 advocacy for optometry, but also launching an unprecedented, multifaceted relief and recovery package.

Given the evolving nature of this pandemic, the AOA remains committed to providing the most up-to-date information, relevant care guidance and resources, and timely reports on federal actions through AOA's COVID-19 Crisis Response page. This online resource includes:    

• New recommendations for the reactivation of optometry services in the form of AOA's Optometry Practice Reactivation Preparedness Guide.
• The AOA Health Policy Institute's "Doctors of Optometry and COVID-19" statement and FAQ.
• #AskAOA COVID-19 webinar series.
• State-by-state COVID-19 resources and information.
• Latest information from CDC and White House Coronavirus Task Force.