Second Open Door on Rebid: Bids ‘Must Be Realistic’
BALTIMORE — On Wednesday, CMS held its second in a series
of eight Special Open Door Forums on the Round 1 rebid titled
“Learn the Rules to Submit a Bid Successfully.”
Cindy Dreher, content and policy lead for the Competitive
Bidding Implementation Contractor, gave an overview of competitive bidding areas,
product categories and rules providers must follow when submitting
bids. Among the items in Dreher’s presentation:
-
The name of the Miami-Fort Lauderdale-Miami Beach CBA has been
changed to Miami-Ft. Lauderdale-Pompano Beach, but the geographic
area remains the same. -
If zip code changes have occurred since Round 1, such as one zip
code that has been split into two, then both are now included in
the CBA. If a zip code was deleted completely, then that zip code
has been removed from the CBA. No new zip codes have been added
that would expand the areas of a CBA. -
The Round 1 rebid will be conducted for essentially the same
HCPCS codes as Round 1 in 2008, with the exception of negative
pressure wound therapy and Group 3 complex rehab power wheelchairs,
which are excluded permanently from competitive bidding. There are
also exceptions for obsolete codes and codes no longer separately
payable, such as oxygen accessories. -
Diabetic testing supplies comprise the only mail order category.
“This does not include items obtained by beneficiaries from local
storefronts,” Dreher said. Beneficiaries may choose to obtain their
diabetic test supplies from storefronts, which may or may not be a
contract supplier, or by mail from a contract supplier. Mail order
supplies can be delivered by common carriers such as the USPS,
FedEX or UPS, but not by store employees in company-owned or
personal vehicles. -
Any Medicare-enrolled DMEPOS supplier that meets requirements
can bid. “Suppliers do not have to be physically located in a CBA
to submit a bid for that CBA. However, any supplier must meet
quality standards, accreditation and licensure requirements for
that product category in that CBA to submit a bid in that CBA,”
Dreher said. All required licenses must be on file with the NSC
before bid submission. Providers bidding outside a CBA must be able
to serve the CBA from an existing location. -
If a CBA includes more than one state, the bidder must be
licensed in each state included in the CBA. -
Suppliers serving as subcontractors must be accredited. Winning
suppliers must notify CMS of subcontracting arrangements within 10
business days of the contract award or of entering into a
subcontracting agreement. -
Rental payments for months 1-3 will be equal to 10 percent of
the median winning purchase bid. For months 4-13, payments will be
based on 7.5 percent of the median winning bid. Payments over the
13-month period will equal 105 percent of the median winning
bid. -
All bid amounts must be “bona fide, feasible or realistic,”
Dreher said, and bidders must be able to support the bid with a
manufacturer invoice or other documentation that verifies the item
can be purchased for that amount. “Loss- leader bids, where an
extremely low bid amount is submitted for one item and other items
are realistically bid, are not acceptable,” according to
Dreher. -
If the amount for one item in product category is found to be
not “bona fide,” then that bid for that category will be
disqualified. “It’s critically important that the bid amount be
very carefully reviewed before bid application is certified and
before bidding closes,” explained Dreher. -
Financial documentation requirements will be discussed in a
future Open Door session. -
Of the 638 listeners on the call, several providers raised
questions about the teleconference topics that drew these answers
from CBIC and CMS officials.
Q: For CPAP, will Medicare consider the costs involved
under new patient compliance requirements, such as revisiting the
patient to download data and coordinating the patient’s
follow-up?
A: Those services you mentioned are included in
the fee schedule amount. This is current policy.
Q: If a provider in Pensacola wants to bid oxygen in
Miami, which is nine hours and 600 miles away, is there anything
the Pensacola provider needs to do besides have a state oxygen
license to be qualified to bid in Miami?
A: You can bid in a CBA where you don’t have a
physical location, but your existing locations must be able to
provide all required services.
Q: Is there anything else they need to do to prove they
can serve that CBA? As long as they say they can do it, they can do
it?
A: As long as they comply with supplier
standards.
Q: Do you have to be licensed in each state for mail
order diabetic supplies? Some states require a physical location
for licensure, which would preclude some mail order suppliers for
providing to patients in those states.
A: The rule is you have to be licensed to
provide that specific product category in that specific state if
that state requires that license.
Q: Have you heard from accreditation organizations that
they are having problems meeting deadlines, with subcontractors
especially?
A: The accreditors are on target. Regarding
subcontractors, there will be further guidance coming out. “We will
have a DME Open Door Forum next Wednesday, so stay tuned there,”
said CMS’ Sandra Bastinelli.
To listen in on the Sept. 9 Open Door, scheduled from 2 to 3
p.m. ET, call 800/837-1935 and reference Conference ID
22139267.
For further information on the Round 1 rebid, see the CBIC Web
site at http://www.dmecompetitivebid.com.
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