CMS and AAHomecare Meet to Analyze Industry ANPRM Comments

As part of its continuing collaboration with CMS, AAHomecare staff met with CMS officials on June 4 to review in detail the comments submitted in response to the Advance Notice of Proposed Rulemaking (ANPRM) for the expansion of the Medicare bidding program. AAHomecare, along with a wide array of clinicians, advocates for Medicare patients, as well as home medical equipment providers, manufacturers and trade groups, submitted comments in response to the ANPRM in March.

AAHomecare CEO Tom Ryan, Jay Witter, senior vice president of public policy, and Kim Brummett, vice president of regulatory affairs, were on hand to advocate for the industry’s positions on bidding expansion. AAHomecare presented an analysis of all comments submitted to CMS. The analysis clearly showed that more than 90 percent of submissions were opposed to potential bundling of DME as indicated in the ANPRM. The overwhelming opinion was that the program was too new to tout as a success, much less implement CB pricing more broadly.

The examination of key takeaways from the ANPRM comments included reinforcing the request for a delay in issuing a proposed rule until two expected OIG reports are released, that SPA prices are not reflective of provider costs, reinforcing the need for Medicare beneficiaries to own customized, single patient use equipment. The many concerns regarding the impact of bidding on rural areas were also reiterated.

AAHomecare also pointedly brought up the documentation requirements related to medical necessity and the impact this will have on the potential bundling. AAHomecare was clear that bundling does not provide flexibility for Medicare beneficiaries to switch providers or relocate.

“The ANPRM comments, coming from a variety of individuals and organizations, offer further evidence that the CMS bidding program endangers patients and needlessly puts providers out of business,” said Ryan. “CMS and Congress should be focused on fixing these problems so that senior citizens and others living with disabilities—some of the most vulnerable people in our society—receive adequate goods and services. We need to stop the rush to expand, and make the current program work properly.” Visit aahomecare.org for more information.