{"id":14345,"date":"2018-09-13T14:10:17","date_gmt":"2018-09-13T18:10:17","guid":{"rendered":"http:\/\/www.medicareadvocacy.org\/?p=14345"},"modified":"2018-09-13T14:56:45","modified_gmt":"2018-09-13T18:56:45","slug":"center-comments-on-proposed-dmepos-rules","status":"publish","type":"post","link":"https:\/\/medicareadvocacy.org\/center-comments-on-proposed-dmepos-rules\/","title":{"rendered":"Center Comments on Proposed DMEPOS Rules"},"content":{"rendered":"

September 10, 2018<\/p>\n

Centers for Medicare & Medicaid Services
\n\tDepartment of Health and Human Services
\n\tAttention: CMS-1691-P
\n\tMail Stop C4-26-05
\n\t7500 Security Boulevard
\n\tBaltimore, Maryland  21244-1850<\/p>\n

Submitted electronically to:<\/strong> http:\/\/www.regulations.gov<\/a><\/p>\n

Re:  CMS-1691-P; Federal Register, Volume 83, No. 139 (July 19, 2018)<\/strong><\/p>\n

The Center for Medicare Advocacy (the Center) provides these comments regarding CMS-1691-P and the impact of the proposed rule on beneficiary access to Durable Medical Equipment Prosthetics, Orthotics and Supplies (DMEPOS).<\/p>\n

The Center, founded in 1986, is a national, non-profit law organization that works to ensure fair access to Medicare and quality healthcare. The organization provides education, legal assistance, research and analysis on behalf of older people and people with disabilities, particularly those with long-term conditions. The Center’s policy positions are based on its experience assisting thousands of individuals and their families with Medicare coverage and appeal issues. Additionally, when necessary, the Center provides beneficiaries with individual and class action representation to address broad patterns and practices that inappropriately deny access to Medicare and necessary care. The Center also participated on the Technical Expert Panel convened in February 2018 to discuss issues related to this proposed rule.<\/p>\n

The proposed rule seeks to make technical amendments to correct existing regulations related to the Competitive Bid Program (CBP) for certain DMEPOS and proposes to change bidding and pricing methodologies. CMS receives beneficiary, provider and supplier feedback about how current and proposed bidding and pricing policies have, and in the future may, impact them. The Center has experience with beneficiary access problems, hospital discharge planners’ feedback, home and community based advocate information, and suppliers’ struggles to adapt to competitive bid realities and ensuing difficulties meeting patient needs. Changes in bidding and pricing methodologies require careful consideration to avoid unintended consequences that may further hinder beneficiary access to reasonable and necessary DMEPOS.<\/p>\n

To summarize, the Center respectfully requests that CMS act as follows:<\/p>\n