Uncertainty & Burden
CMS’s competitive bidding process placed an extraordinary burden on suppliers in terms of providing financial information and, to make matter worse, CMS was vague and ambiguous in defining how it would use this financial information.
In the initial round of bid submissions, I worked with many suppliers in helping them to interpret what financial information was required, in advising how they could develop this information in the format demanded and counseling them on how CMS might or could utilize the information. I can assure you that the amount of time and expense consumed by requiring this information was very significant. In most cases, outside accounting firms were called in to help or prepare information, adding a real incremental expense for the suppliers. Significant internal time was invested. It is unclear to me if CMS spent any time or effort trying to understand how significant its requirements were and how much time and money was devoted to adhering to the requirements for financial information.
Exacerbating the concern over time and money used to fulfill financial reporting requirements is the fact that CMS repeatedly refused to inform the prospective bidders exactly how the information would be used. CMS’s clearly used a threatening and intimidating approach in telling suppliers that they could be disqualified from bidding if their financial information failed to meet the CMS standards. But never did CMS publish its standards – that seems incomprehensible. The CMS bidding process puts a supplier’s entire business at risk; failure to win the bid would be extremely detrimental to the supplier, yet left them hanging on this critical criteria. CMS should be required to operate with bidding rules and criteria fully exposed to the light of day, otherwise the integrity of their entire process will be in question.