Discussion Forum

It is essential that members of the regulated community supplement information presently before CMS.

The following post is on the home page of the IPD. We encourage our readers to address this issue.

CRE’s Data Quality Alert emphasized the need for reliable data on a number of specific issues including “supplier capacity.” This term refers to CMS’ estimates of the ability of bidders to meet projected demand for DMEPOS items within a Competitive Bidding Area (CBA). CMS’ planned methodology for estimating supplier capacity includes looking “at trend data for new suppliers in that area, and examine the capacity of other … Continue Reading

After the end of the public comment period up through the publication of a final rule, the government has a monopoly over the regulatory process. In essence the public, including the regulated community, is shut out of the process.

The same problem occurs after a rule is promulgated and the agency goes into program implementation; in this instance the agency makes numerous decisions which could not have been envisioned at the time of the NPRM.

In our wired society, the generation of information on a regulatory issue does not cease at the end of a public comment period. In essence, the sixty … Continue Reading

On June 19, 2008, GW’s Department of Health Policy stated:

“This analysis shows how the competitive bidding program makes an already vulnerable population even more vulnerable. Medicare must immediately take steps to help seniors with diabetes avoid confusion and ensure that their treatments are not interrupted,” said Sara Rosenbaum, JD, Hirsh Professor of Health Law and Policy and chair, Department of Health Policy, and lead author of the study.

The conclusions of this study are counter to the thrust of the CMS rule; readers are encouraged to review the attached study and submit their commments hereto. (Please note that in submitting comments,  authors … Continue Reading