AAH urges caution in comments
WASHINGTON - In 20 tightly packed pages of comments submitted to CMS by the June 30 deadline, AAHomecare raised plenty of concerns over Medicare's draft plan to implement competitive bidding for DME.
Of utmost importance: CMS should revise its timeline to make sure it has time to do all that's required by year's end. Among other things, CMS must select accrediting bodies, publish product categories, evaluate bids and educate beneficiaries and referral sources.
With so much unexplained, AAHomecare urged CMS to provide the industry with another opportunity to submit comments. Once CMS has published more information, it should issue an interim final rule and request a meeting of the Program Advisory and Oversight Committee (PAOC) on competitive bidding.
AAHomecare also made the following comments:
The draft states that CMS will allow a "grace period" during which unaccredited providers can participate in the bidding process. If it fails to get accredited during the grace period, the bidder will loose its contract supplier status. Whether a supplier is accredited influences its bid amount inasmuch as accredited suppliers must bear the cost of complying with the quality standards. These costs are unknown until CMS publishes final quality standards. Consequently, unaccredited suppliers who lack experience with accreditation will not be able to accurately project those costs, skewing the pivotal bid point and the median bid downward.
CMS's proposal to allow contract suppliers to offer rebates fundamentally conflicts with the longstanding rationale underlying the prohibitions on inducements and kickbacks in federal healthcare programs. This type of activity distorts patient decision making and undermines true competition among healthcare providers.