Check Rebid Paperwork Once, Twice, then Check Again

BALTIMORE — Providers looking to capitalize on CMS’ Nov.
21 covered document review deadline (11:59 p.m. Saturday) for the
Round 1 rebid might want
to check instructions once more before submitting financial
documents. After all, those who decide to get things in early could
miss out on crucial information such as that uncovered by the
Florida Alliance of Home Care Services.

After months of attempting to gain clarity from CMS on the issue
of submitting financial statements with competitive bid
applications, last week FAHCS associate member Javier Talamo of
Hialeah, Fla.-based Kravitz and Talamo received the following
response (excerpted here) from the Competitive Bidding
Implementation Contractor.

Dear Mr. Talamo:

Your financial statements (income statement, balance sheet,
and statement of cash flow) must coincide with your usual year end,
regardless of when you submit the documents to the CBIC. For
example, if you report on a calendar year (January 1 through
December 31), then your financial statements should be for the 12
months ending December 31. However, if you report on a fiscal year
(such as October 1 through September 30), then the financial
statements should be for the fiscal year end. The reporting period
that you use for your financial statements should coincide with the
reporting period for your tax return.

In a listserv message sent out Friday, the CBIC noted “that CMS
is in the process of updating its instructional materials to
emphasize that all financial documents must be for the same
accounting period (calendar or fiscal).”

Other tips from the CBIC in submitting documentation:

• Review the RFB instructions carefully to be sure that your
  documents comply with all requirements.

• Put your bidder number on every page of every document.

• Submit all required hardcopy documents in one package.

Unlike last year, bidders who turn in their paperwork prior to
the document review date will get a crucial heads-up from CMS that
could mean the difference between winning and losing a bid. CMS
will not, however, be checking to see if the documents are
acceptable, accurate or meet applicable requirements.

“Suppliers that submit documents by the covered document review
date will be notified of any missing financial documents within 45
days of the covered document review date,” said CMS Official Martha
Kuespert in a recent Open
Door Forum call on the rebid. “Suppliers will then be required
to submit the missing financial documents within 10 business days
of the notification.

Veterans of last year’s Round 1 — in which 630 out of
1,105 bidders were disqualified, many for missing documentation
— are all too familiar with last-minute corrections. Provider
Roger Ribas, president of FAHCS, said more could be on the way,
although it’s impossible to know for sure.

“It does not surprise me that CMS is clarifying something in the
middle of the process,” said Ribas. “People are so sensitive that
they are not going to get [the documentation] right that we had to
wait and get some kind of clarification from CMS on something as
basic as [the appropriate time periods for financial statements].
It really just shows you how a simple mistake can cost a company
their whole livelihood.”

While providers grapple with the prospect of getting precisely
the right documentation, the industry at large continues to spread
the word about the negative impact of competitive bidding on
patients and providers. AAHomecare’s Web site lists a number of
possible problems that advocates believe will crop up yet again
during the Round 1 repeat. Problems in the original bid
included:

• Disruption to patient services. Patients were
  forced to go to multiple, unfamiliar providers for different items
  and services. Informal surveys showed that some winning providers
  were unable to provide care to beneficiaries.

• Greater costs to Medicare due to longer hospital
  stays . Confusion about the restricted list of contracted
  home medical providers delayed hospital discharges and triggered
  unnecessary emergency room visits.

• Non-local providers. Providers with no history
  of servicing a geographic area or no operations in a bidding area
  were awarded contracts.

• Inexperienced/unlicensed providers. Companies
  were awarded Medicare contracts to provide equipment and services
  for which they were not licensed and had no previous experience
  providing.

• Desperation bidding. Structural flaws in the
  bidding program caused providers to submit artificially low bids
  because they were faced with the threat of losing their businesses
  if not awarded a contract. Winning contracts also were viewed as
  commodities that could be sold once a bid was won.

Check the CBIC Web site for a covered document review date fact sheet.

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