CRE has compared the rules covering competitive bidding in the Medicare Advantage program with the competitive bidding rules governing the medical equipment program.
CRE concludes in correspondence to the Deputy Director of OMB that the competitive bidding proposal in the Medicare Advantage program is similar to that recommended by CRE in that it would be used to set prices but would not be used to determine which companies are eligible to compete within the program.
CMS can not initiate the competitive bidding program until OMB approves its information collection request ( ICR) pursuant to the Paperwork Reduction Act. CRE has identified a number of deficiencies which demonstrate that the CMS ICR is not PRA compliant.
CRE also recommends a solution to the problem: allow all qualified small suppliers to provide equipment at the single payment amount if the suppliers meet the SBA definiton of a small business.
CRE comments are appended hereto.