WASHINGTON, D.C. (September 20, 2019)—The 2020 ESRD/DMEPOS Proposed Rule that was published on Aug. 6, includes changes to the gap filling framework, payment conditions, and change of ownership (CHOW) timeline. Below are high-level points AAHomecare will be making:


The current Medicare gap fill methodology is out of date, insufficient and significantly flawed. AAHomecare strongly opposes CMS’s proposal to codify the flawed gap-filling pricing policies in federal regulation. Instead, the association urges CMS to implement a process that involves all stakeholders, including experts, and is completely transparent.


Overall, AAHomecare supports CMS’s proposal to create this single “Master List,” but there are a number of concerns regarding the notice, timing and transparency associated with the “Master List” and the “Required List.”


AAHomecare supports the proposal to extend the CHOW timeline from 60 days before the effective CHOW date to 10 days after the effective date.

This is intended to provide guidance for AAHomecare members interested in submitting comments. Comments are due Sept. 27. Providers can submit comments at regulations.gov. The association will share final comments with membership before the due date.

See AAHomecare’s summary on the proposed rule for additional perspective.

MedPAC Suggests Expanded Scope for Bidding Program

On September 5, MedPAC, an influential commission consisting of Medicare experts in finance and health care delivery, held a discussion on the Competitive Bidding Program (CBP). The discussion specifically focused on the impact of diabetic testing supplies in the national mail order program and expanding the competitive bidding program. Overall, the commission believes CBP to be a major success for Medicare. Spending for CBP items was reduced by 62% between 2010 to 2017, and this decrease is even greater for diabetic testing supplies at 88%. CMS’s data shows that there were no adverse health effects due to competitive bidding, and therefore the commission is interested in increasing CMS’s authority to expand CBP to other DMEPOS items and other health care services.

You can find MedPAC’s presentation here and the full transcript of the discussion starting on page 117.