Give Them a Piece Of Your Mind

CMS is asking how you would do it. That’s right. CMS wants to know how you would handle competitive bidding — what you think about its method of selecting cities where the program will begin, how products will be chosen for inclusion in the bid and how payments will be set.

And the agency is asking if you have any better ideas.

Of course it would be nice if you could just say, “Don’t do it.”

In fact, HomeCare has received questions from several stakeholders asking why CMS — as it has so often — doesn’t simply lower reimbursements to achieve the savings it needs instead of going through all of the upheaval that competitive bidding will cause: the business and job loss throughout the industry, the loss of access for beneficiaries, the millions of dollars it will cost the government to administer the program.

But, the agency points out, since Congress has mandated competitive bidding for DMEPOS through the Medicare Modernization Act, CMS is charged with carrying it out. Thus, you can see how CMS is proposing to implement the bidding program in its Notice of Proposed Rulemaking.

You can download a PDF of the NPRM at www.cms.hhs.gov/CompetitiveAcqforDMEPOS. Make sure your printer is fully loaded with paper — it’s 203 pages long.

I must warn you that it’s frustrating reading. But keep going. Buried deep within the document on page 156, there is one part that you shouldn’t miss. In the section titled “Effect on Suppliers,” CMS notes that when all its rules are fully implemented and the program is in place, it expects there will be 50 percent fewer DMEPOS providers doing business with Medicare than currently exist.

How could that be, you might ask? Remember that if you are not selected as a winning bidder in your area, you will not be able to provide the items that are included in Medicare’s bidding program — and beneficiaries won’t be able to buy those items from your company even if they want to.

Most in HME agree this is very scary stuff both for you and your patients. So if you’ve got ideas about how the competitive bidding proposal might be changed or improved, don’t keep them to yourself. Let CMS know.

You can submit your comments electronically, by regular mail or overnight mail, or you can deliver them by hand or through a courier. Here’s how:

• Send electronic comments through www.cms.hhs.gov/eRulemaking.
• Mail written comments (with one original and two copies) to: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1270-P, P.O. Box 8013, Baltimore, MD 21244-8013.
• Send express or overnight letters to: CMS-1270-P, Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1270-P, Mail Stop C4-26-05, 7500 Security Blvd., Baltimore, MD 21244-1850.
• To hand-deliver written comments or send them by a courier, you must phone first to 410/786-7195 to schedule arrival. Comments can be delivered to: Room 445-G, Hubert H. Humphrey Building, 200 Independence Ave., SW, Washington, DC 20201; or 7500 Security Blvd., Baltimore, MD 21244-1850.

CMS will accept your comments through June 30.