Bidding and bundling: Providers heed call to comment

Friday, September 5, 2014

WASHINGTON – Industry stakeholders say a large number of providers answered the call to submit comments by Sept. 2 on a proposed rule to, among other things, expand the competitive bidding program nationwide.

More than 4,000 comments were submitted on the overall rule, and stakeholders believe a good number of them pertained to the bid expansion and another HME provision to create bundled monthly payments.

“The feedback we’ve gotten from providers spoke to rural healthcare access,” said John Gallagher, vice president of government relations for The VGM Group. “The comments were diverse—from the guy who can no longer go out to islands off of Cape Cod to the guy in Montana who covers a 400-mile radius and can no longer cover Indian reservations.”

CMS published the rule in the July 11 Federal Register.

Stakeholders planned to sift through the comments as a strategic exercise, looking to see where they agree and don’t agree with other commenters.

“We like to analyze comments, to see if there’s a theme and to maybe reach out to other associations whose comments didn’t align with ours to get feedback,” said Kim Brummett, senior director of government affairs for AAHomecare.

Of course, it’s one thing to comment en masse, it’s another thing for CMS to take notice. Brummett pointed to the *advance notice of proposed rule, published in February, as an example.

“Not one comment on that ANPR said that bundling enterals was a good idea and they listed the reasons why,” she said. “CMS went ahead and included it anyway.”