Statement from the National Home Infusion Association on CMS’s Proposed Changes to the DMEPOS External Infusion Pump Criteria

The National Home Infusion Association (NHIA) appreciates CMS’s recognition in the Calendar Year 2027 Home Health Prospective Payment System (HH PPS) Rate Update; Requirements for the HH Quality Reporting Program and the Expanded HH Value-Based Purchasing Model; Medicare Provider Enrollment, Durable Medical Equipment (DME), and DME, Prosthetics, Orthotics, and Supplies (DMEPOS) that registered nurses and other qualified clinicians are well-equipped to safely manage the monitoring and potential adverse effects associated with infusion therapies furnished in the home. This acknowledgement reflects decades of clinical experience demonstrating that home infusion providers routinely deliver complex intravenous medications safely through comprehensive patient assessment, education, monitoring, and coordination with prescribing clinicians. CMS appropriately reinforces what home infusion providers, physicians, and patients have long known—that clinically appropriate infusion care can be delivered safely in the home with qualified healthcare professionals overseeing patient care.

However, this proposal to modify the criteria for the use of an infusion pump should not be viewed as a solution to the broader access challenges facing Medicare beneficiaries who could safely receive infusion therapy at home. The overwhelming majority of Medicare beneficiaries continue to lack meaningful access to home infusion because of fundamental flaws in the Medicare home infusion benefit. As a result, thousands of beneficiaries receiving intravenous anti-infectives, hydration, immune globulin, biologics, and other infused medications continue to be directed to hospital outpatient departments and skilled nursing facilities despite home infusion often being the clinically appropriate, lower-cost, and patient-preferred setting.

The limited impact of this proposal underscores the much larger disparity that continues to exist between Medicare and the commercial insurance market. Today, over 350 infused drugs are routinely administered safely in patients’ homes under commercial insurance coverage. By contrast, CMS acknowledges in the proposed rule that only a single drug is expected to newly qualify for Medicare coverage under the revised external infusion pump criteria. While NHIA supports expanding access for any beneficiary who may benefit from this policy, the proposal fails to meaningfully narrow the significant access gap between Medicare beneficiaries and commercially insured patients.

To more fully address the disparity in access between Medicare and commercial coverage, NHIA urges Congress to enact the Preserving Patient Access to Home Infusion Act (H.R. 2172, S.1058), legislation that would address the structural deficiencies in the Medicare home infusion benefit by ensuring beneficiaries can receive the professional services necessary to safely administer infused medications in their homes. Passage of this legislation would substantially expand access, improve patient choice, reduce unnecessary utilization of higher-cost sites of care, and better align Medicare policy with today’s clinical standards.

NHIA looks forward to continuing to work with CMS and Congress to ensure that all Medicare beneficiaries—not just the small number affected by this proposal—have access to safe, high-quality home infusion services when clinically appropriate.