• 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 “


    This  group should supplement the following comment:
    “CMS issued important and substantive competitive bidding rules via sub-regulatory process that was not subject to appropriate oversight by Congress or the scrutiny that comes from a public comment period.” 

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