Comments Submitted to CMS by the American Association for HomeCare

Individuals wishing to comment on these comments can do so by merely clicking on the comments link in the upper left hand side of this post

Interesingly, the comments of the  American Association for Homecare hightlight the need for an IPD on this rule because of the constantly changing information:

“CMS issued a final rule on competitive bidding that addressed only the broad framework of the program while giving itself vast discretion to evaluate bidders on subjective factors such as quality or financial soundness based on criteria that were not identified in the rule. Instead, many of the substantive requirements for bidding were issued informally – either verbally during CMS contractor teleconferences or through written questions and answers posted on the contractor’s website, completely by-passing the rulemaking process.^{3 “}

CMS Reimbursement Rule

The attachment hereto is the rule which the subject of the comments submitted by the respondents in this Interactive Public Docket.

Individuals or organizations who have additional concerns or new information should post articles or comments in the Discussion Forum which is  located on the upper right hand side of this page. Annoymous comments are accepted.

Individuals who wish to make a less formal statement can do so by clicking in the email icon located in the upper right hand corner of this page.  All comments are assumed to be comments made to the public.

Comments Submitted to CMS by the Diabetic Product Suppliers Coalition

The Coaltion concludes:

CMS’s apparent haste to enact a Competitive Bidding Program that is nearly identical to the program that was initially implemented for rollout in 2007-2008, including almost all of the same flaws, is at odds with Congress’s decision to delay the Program’s implementation through the passage of MIPPA.

Comments Submitted to CMS by the Medicare Payment Advisory Commission

The Commission concludes:

Competitive bidding for DMEPOS appears to be a promising way to improve the accuracy of  Medicare’s payments for these services.

Comments Submitted to CMS by Bayer

Bayer makes two key arguments in their comments: 1) maintaining the pharmacist-patient relationship is crucial to the health of diabetes patients; and 2) implementing competitive bidding for diabetes supplies would significantly undermine this relationship.  Bayer cites two primary implications of harming the pharmacist-patient relationship: 1) reduced health quality for diabetic patients; and 2) increased expense to the federal government for treating more severe complications of diabetes

Comments Submitted to CMS by Byram

Comments Submitted to CMS by the Jefferson Health Group

This comment will  be of particular interest to economists. In making its arguments, Jefferson states:

” A study by Carnegie Mellon econmists, widely circulated within the industry cited the “franchise Fee” economic theory,  which noted that once bids were secured, that numerous small bidders will leave the industry, yielding at an oligopoly of power in each bid area, if not a defacto monopoly power to the award winners.”

Jefferson is making important macro arguments which should have a particular impact with regulators.

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