CMS's crazy train leaves the station
It's not much fun anymore criticizing CMS for being a bumbling, stumbling government bureaucracy. It used to be fun, in a sort of self-satisfied way. CMS officials would come out with some half-baked policy or reimbursement change (inherent reasonableness, for example) unsupported by any kind of definitive data, and it was a simple task to point out the errors of their ways. It's still a simple task, but it's no longer fun. It's maddening and a little disturbing.
CMS has unnecessarily turned the HME industry upside down. Whether it's eliminating the CMN for power wheelchairs, proposing to decrease the dispensing fee for respiratory meds, increasing without any warning the number of codes for power operated vehicles or developing an unworkable set of quality standards, CMS has yet to demonstrate competence, fairness or honesty -- all bedrock American values.
Maybe the agency is overworked and under staffed. That would explain why it frequently floats a policy change, sets a deadline and then, realizing it's created more questions than answers, delays that deadline. That would also explain why CMS regularly gathers insufficient market data to support proposed reimbursement cuts. Being understaffed might also explain why CMS continues to use gap filling - the methodology for calculating new fee schedules - even though agency officials acknowledge it is flawed and inaccurate.
Whatever the case, overworked or incompetent, for the foreseeable future, providers must understand one thing: You can't count on CMS to do the right thing. Industry leaders have done a good job lobbying to slow down CMS's crazy train. As a provider, the delays allow you time to become more efficient and decrease your Medicare business.
What other choices do you have?
The charitable position is to give CMS the benefit of the doubt, that it means well and will listen to reason. But that only works up to a point, and then you start to feel like a schmuck.