The 746,240 Fee Amounts Medicare Left Alone

CMS issued Transmittal 13956 this morning, Change Request 14619, the October quarterly update to the DMEPOS fee schedule. Effective Thursday, implementation the following Monday.

Before reading it we pulled the three quarterly files CMS has already published this year and diffed them against each other. January, April, July.

Same 114-column layout, same 53 jurisdictions, same non-rural and rural pair on every one.

"How much does a quarterly fee schedule update actually change a fee?"

Nothing. Not one amount, in either transition, out of 746,240 compared (chart below).

January to April, 3,509 rows appear in both files and all 114 fields match on every single one. 371,954 non-blank fee amounts, zero changed. April to July is starker: no rows added, none removed, and 3,529 of 3,531 rows identical field for field. The two that differ differ in the descriptor text only, both of them transanal irrigation items whose short descriptions got rewritten while their prices sat still.

The change file CMS promises and does not ship

The layout document riding inside each of those ZIPs says this, verbatim:

"Additionally, when a quarterly release occurs, DMECHNG (in Excel (.xls) and comma delimited (.csv) formats) identifies the fees which have changed during that quarterly update."

There is no DMECHNG file in the January ZIP, the April ZIP, or the July ZIP. Twenty files, seventeen, seventeen, and the change log is in none of them.

So the absence is not an oversight anyone needs to chase. CMS ships a change file when there are changes, and this year there have not been any.

The same document calls the process "semiannual or quarterly (as necessary)," and as necessary has been doing quiet work.