Comments

Comments to CY2020 ESRD / DMEPOS Competitive Bidding

The Coalition submitted comments to the DMEPOS Competitive Bidding Proposed Amendments included in CMS's CY 2020 End-Stage Renal Disease Prospective Payment System. In comments specifically focused on the provisions related to "Establishing Payment Amounts for New Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) Items and Services (Gap-filling)," the Coalition counseled CMS on a number of issues, flagging concerns and suggesting solutions:

• CMS should not move forward with a final rule on payment methodologies for DMEPOS until further work is completed.
• CMS should work with stakeholder groups and experts outside of CMS to ensure that the agency has a sufficient understanding of all costs associated with the provision of wound care products and other various types of technology classified under the DMEPOS benefit.
• The Medicare “gap filling” payment determination methodology must be replaced as it is archaic, and does not result in reimbursement rates that allow access to medically necessary technology.
• Fee schedules developed through comparable technology or technology assessments should be transparent and should include manufacturer’s input to ensure a thorough understanding of all associated costs.
• CMS should institute an efficient and expeditious appeals process for manufacturers to challenge reimbursement levels established by this new pricing methodology and gap filling.
• HCPCS public meetings should be limited to input on HCPCS codes, which are universal and as such should be focused on needs of all payers.

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Comments to Interim Final Rule on Durable Medical Equipment Fee Schedule Adjustments

The Coalition submitted comments to CMS on the agency's DME Interim Final Rule- which addresses competitive bidding issues. Within the interim final rule, published in May, CMS temporarily increases the fee schedule rates from June 1, 2018, through December 31, 2018, for certain durable medical equipment (DME) items and services and enteral nutrition furnished in rural and non-contiguous areas (Alaska, Hawaii, and U.S. territories) of the country not subject to the Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Competitive Bidding Program. 

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Comments to CMS on Medicare Program Durable Medical Equipment Prosthetics, Orthotics, and Supplies (DMEPOS) Competitive Bidding Program Bid Surety Bonds, State Licensure and Appeals Process for Breach of Contract Actions, Durable Medical Equipment, Prosth

The Coalition submitted comments to CMS on CMS-1651-P: Medicare Program Durable Medical Equipment Prosthetics, Orthotics, and Supplies (DMEPOS) Competitive Bidding Program Bid Surety Bonds, State Licensure and Appeals Process for Breach of Contract Actions, Durable Medical Equipment, Prosthetics, Orthotics and Supplies Competitive Bidding Program and Fee Schedule Adjustments, Access to Care Issues for Durable Medical Equipment, stating that while the Coalition agrees with some provisions that CMS has adopted regarding the competitive bidding program, significant problems remain. Specifically, the Coalition is concerned that CMS does not do a sufficient job vetting vendors for the competitive bidding program or ensuring the implementation of quality standards and products. The Coalition also takes issue with CMS’s decrease in reimbursement for NPWT, as the ramifications of that decrease can have devastating impacts on rural communities.  
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Comments on CY 2015 End-Stage Renal Disease Prospective Payment System and Durable Medical Equipment Prosthetics, Orthotics, and Supplies, Proposed Rule

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Comments to CMS on Proposed Methodology for Adjusting Payment Amounts for Certain Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) using Information from Competitive Bidding Programs

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