From the Editor: Dog Days

Wednesday, August 31, 2005

You've got to wonder if the folks at CMS and the DMERCs are feeling the heat of the multiple HME deadlines and decisions they've got hanging over their heads. If they're not, they should be.
In most years, having to cook up a draft competitive bidding program would be enough of a challenge for Medicare bureaucrats. This fall they've got to do that and much more. Before Jan. 1, 2006, they've also got to develop a new fee schedule for Medicare's 49 new wheelchair codes and determine a new dispensing fee for nebulizer meds. The DMERCs have to crank out a local coverage determination for mobility assist devices (manual and power wheelchairs and scooters). The Aug. 1 deadline for a draft LCD has already come and gone. Not a good sign.
CMS has its hands full, to say the least, and in those hands sit the futures of many an HME provider. Put out a too-low dispensing fee and providers, unable to turn a profit, flee the business. Develop new wheelchair allowables based on a faulty methodology (gap filling) and the result could be worse: inadequate reimbursement to the point that providers turn out their lights altogether and go find something else to do. Neither bodes well for beneficiaries.
We know what CMS should do: Take its time and develop commonsense policy and regulatory changes that are fair and based on solid clinical and market data. Surely that is what CMS officials want to do. It is, after all, the responsible thing to do. But do they have the time to do so? If not, they need to push back some deadlines and concentrate on one thing at a time. It's much like the old adage: When you are building something:,measure twice, cut once. For CMS, these really are the dog days. We just hope the heat doesn't go to their heads.
There is not a moment to lose for providers to begin contacting and educating their representatives on a bill now in Congress that would make the dreaded reimbursement cut much less onerous to small HME companies. Whether or not this bill passes could very well determine how much longer you'll be an HME provider. For more on this, see Denise Fletcher's Smart Talk column.