CMS Announces Timeline for Next Phase of DMEPOS Competitive Bidding

CMS has announced its detailed timeline for recompeting the supplier contracts awarded under Round 2 of the Medicare Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Competitive Bidding Program and the National Mail-Order diabetic testing supplies competition. All current Round 2 and National Mail-Order diabetic testing supplies contracts will be up for rebidding. The current contract period expires on June 30, 2016; the new contracts will begin on July 1, 2016. The first key date in the recompete cycle is December 18, 2014, when supplier registration for bidding opens, and the actual bid window opens on January 22, 2015. The full timeline is as follows (note that dates are subject to change):

12/18/2014 -- Registration for user IDs and passwords opens
1/6/2015 -- Authorized Officials strongly encouraged to register no later than this date
1/20/2015 -- Backup Authorized Officials strongly encouraged to register no later than this date
1/22/2015 -- CMS opens bid window for Round 2 Recompete and national mail-order recompete
2/17/2015 -- Registration closes
2/23/2015 -- Covered Document Review Date for bidders to submit financial documents
3/25/2015 -- Bid window closes
Winter 2016 -- CMS announces single payment amounts, begins contracting process
Spring 2016 -- CMS announces contract suppliers, begins contract supplier education campaign
Spring 2016 -- CMS begins supplier, referral agent, and beneficiary education campaign
July 1, 2016 -- Implementation of Round 2 Recompete & national mail-order recompete contracts/prices

Suppliers considering participating in bidding are encouraged to make sure their enrollment records are up to date with the National Supplier Clearinghouse (NSC) and in the Provider Enrollment, Chain, and Ownership System (PECOS) to prevent being disqualified from bidding. For more information, including a summary of the changes to the product categories and competitive bidding areas in the Round 2 recompete, see our previous overview.  

GAO Analyzes Medicare DMEPOS Competitive Bidding Results

The GAO has released a report entitled “Medicare: Bidding Results from CMS’s Durable Medical Equipment Competitive Bidding Program,” which includes a wide variety of data on level of savings in each bidding round, characteristics of suppliers, reasons for disqualification of bids, and related data. The report does not include recommendations.

OIG Assesses Changes in Medicare Mail Order Diabetes Test Strips Market Share

The OIG has released a report that examines the extent to which Medicare mail order market share for diabetes test strips changed after the start of national mail order competitive bidding for these items on July 1, 2013. According to the OIG, based on a sample of 1,210 claims, there was a somewhat greater concentration of market share three months after competitive bidding contracts went into effect compared to before bidding. Specifically, after competitive bidding was instituted, two types of test strips accounted for 44% of the Medicare mail order market share (up from 34%), three types made up 58% of the market share (up from 51%), and 10 types accounted for 91% (up from 75%). The OIG intends for CMS to use this information to evaluate the effect of the mail order bidding program on the types of diabetes test strips available to beneficiaries, and to assess whether bidders have met their statutory obligations to demonstrate that their bids cover at least 50%, by volume, of all types of mail order diabetes test strips.

CMS Adopts Major Changes to Medicare DMEPOS Payment/Coverage Policy Inside/Outside of Competitive Bidding Areas

This post was written by Elizabeth Carder-Thompson, Carol C. Loepere, and Debra A. McCurdy.

On November 6, 2014, CMS published a final rule that makes significant and highly technical changes to Medicare payment policies for durable medical equipment (DME), prosthetics, orthotics, and supplies (DMEPOS).  Notably, the rule finalizes a new methodology for adjusting Medicare DMEPOS fee schedule payment amounts across the country using information from the Medicare DMEPOS Competitive Bidding Program (CBP). CMS estimates that this methodology will cut Medicare DMEPOS reimbursement by more than $4.4 billion over fiscal years 2016 through 2020. The rule also finalizes a mechanism to test the use of bundled monthly payment amounts for certain DME under competitive bidding; modifies CBP change of ownership (CHOW) and termination of contract rules; and codifies Medicare hearing aid coverage policy. Note that CMS did not adopt its proposal to clarify practitioner qualifications for providing custom fitting services for orthotics. The following is a summary of the final rule, with particular emphasis on revisions to CMS’s July 11, 2014 proposed rule.

Adjustment to DMEPOS Pricing in Non-CBAs.  The Affordable Care Act mandates that, by January 1, 2016, CMS use pricing information from competitive bidding to adjust DME fee schedule amounts for items furnished in areas where the CBP is not implemented. CMS also is authorized (but not mandated) to make such adjustments for off-the-shelf (OTS) orthotics and enteral nutrients, supplies, and equipment furnished outside of competitive bidding areas (CBAs).

CMS has adopted a complex framework and methodology for adjusting fee schedule amounts based on CPB single payment amounts (SPAs), which are the allowed payments for items furnished in a CBA based on the median of successful bids. The primary methodology, which applies a regional adjustment with national limits, will be used for items bid in more than 10 CBAs. In short, CMS will determine adjusted fee schedule amounts for areas within the contiguous United States based on “regional SPAs” (RSPAs) that are calculated from the average SPAs for an item from all CBAs located in the region. The adjusted payment amount for an item will equal the RSPA limited by a national floor and ceiling of not less than 90 percent and not more than 110 percent of the national average. In contrast, in rural areas that have not been subject to competitive bidding, adjusted fee schedule amounts will be based on 110 percent of the national average RSPA (note that in the final rule, CMS adopted an expanded definition of rural areas eligible for this provision). CMS also adopted special rules for adjustments in areas outside of the contiguous United States.

A second methodology will be used for lower-volume items or other items that were bid in no more than 10 CBAs. Payment amounts for these items in non-CBAs will be 110 percent of the unweighted average of the SPAs where CBPs are implemented. CMS provides additional methodologies to account for other special situations, including when the only available SPA for an item is from a CBP no longer in effect, when accessories are used with different types of base equipment, and when SPAs for lower levels of service are higher than SPAs for higher levels of service. CMS also plans to apply national mail order CBP payments to mail order items furnished in the Northern Mariana Islands.

CMS will update adjusted payment amounts each time an SPA changes following a new competition; no inflation adjustment factor will be applied to adjusted fee schedule amounts. The adjusted fee schedule amounts will become the new bid limits for future rounds of competitive bidding.

In response to comments requesting a transition period, CMS has agreed to phase in adjusted payment amounts over six months. Specifically, CMS will make adjustments to the fee schedule amounts for claims with dates of service from January 1, 2016, thru June 30, 2016, based on 50 percent of the un-adjusted fee schedule amount and 50 percent of the adjusted fee schedule amount. The methodology will be fully implemented as of July 1, 2016. CMS offers the following example: if the unadjusted fee schedule amount that would have gone into effect on January 1, 2016 was $100, and the amount resulting from the final rule methodology is $75, the fee schedule amount in effect on January 1, 2016, will be $87.50. Beginning on July 1, 2016, the fully adjusted fees ($75) will apply. According to CMS, this policy “provides suppliers with an adequate amount of time to make adjustments to their businesses in light of the reduced payment amounts and is more than enough time to determine if the payment amounts are impacting access to items and services in any part of the country.”

Special Bundled Payment Rules for Certain DME under the CBP.  CMS is adopting – with revisions – its proposal to test a limited phase-in of bundled payments for certain types of DME subject to competitive bidding, under the auspices of the CMS Center for Medicare and Medicaid Innovation’s demonstration authority. Under the final rule, CMS will provide continuous bundled monthly payments for the equipment, supplies, accessories and any necessary maintenance and repairs for certain items under competitive bidding in place of capped rental policies. CMS will only apply this policy initially to standard power wheelchairs and continuous positive airway pressure (CPAP) devices furnished under the CBP (CMS had initially proposed including a broader array of products in this initiative). CMS will initially test this payment model in no more than 12 CBAs in conjunction with competitions that begin on or after January 1, 2015; any expansion of the program would follow program evaluation and future notice and comment rulemaking.

Under this policy, the SPA for the monthly rental of DME will be based on bids for the monthly rental of DME and all item and service associated with the rental equipment, including all related supplies, accessories, maintenance, and servicing. Separate payment for replacement of equipment, repair or maintenance and servicing of equipment, or for replacement of accessories and supplies necessary for the effective use of the equipment would not be allowed. CMS is also adopting various special transition policies, grandfathered supplier provisions, rules regarding repair and maintenance of beneficiary-owned power wheelchairs, and rules to ensure that bids submitted for items paid on a continuous rental basis are less than would otherwise be paid. CMS will provide advance notice to suppliers and beneficiaries about any special payment rules to be included in a CBP.

DMEPOS CBP CHOW Rules. Current competitive bidding rules prohibit the sale of a competitive bidding contract. Under the current rules, CMS may permit the transfer of a contract to an entity that merges with or acquires a competitive bidding contract supplier, but only if the new owner assumes all rights, obligations, and liabilities of the entire competitive bidding contract.

CMS is adopting its proposal (with technical revisions) to permit transfer of part of a competitive bidding contract under very specific circumstances. Specifically, a contract supplier will be permitted to sell a distinct company (e.g., an affiliate, subsidiary, sole proprietor, corporation, or partnership) that furnishes one or more specific product categories (PCs) or serves one or more specific CBAs and transfer the portion of the contract initially serviced by the distinct company, including the PC(s), CBA(s), and location(s), to a qualified successor entity that meets all competitive bidding requirements. CMS will require a contract supplier that wants to sell a distinct company having a CBP contract to notify CMS 60 days before the anticipated date of a CHOW, and submit any required documentation within 30 days of the anticipated CHOW.

For CMS to approve the transfer, several conditions will have to be met. For instance:

  • Every CBA, PC, and location of the company being sold must be transferred to the new qualified owner.
  • All CBAs and PCs in the original contract that are not explicitly transferred by CMS must remain unchanged in that original contract for the duration of the contract period (unless subject to a subsequent CHOW).
  • All current CHOW requirements set forth at 42 CFR § 414.422(d)(2) must be met.
  • The sale of the company must include all of the company’s assets associated with the CBA and/or PCs.
  • CMS must determine that transferring part of the original contract will not result in disruption of service or harm to beneficiaries.
  • The new supplier must meet all applicable competitive bidding requirements.
  • The contract supplier and successor entity must enter into a novation agreement with CMS, and the successor entity must accept all rights, responsibilities, and liabilities under the competitive bidding contract.

This policy will apply to contracts issued in future rounds of the CPB, starting with the Round 2 Recompete.

Termination of a Competitive Bidding Contract. CMS adopted its proposal to clarify the effective date of “termination” in the termination notice that it sends to a contract supplier found to be in breach of a competitive bidding contract. Specifically, a contract will be terminated automatically if the supplier does not timely file a hearing request or submit a corrective action plan. CMS also will require a supplier whose competitive bidding contract is being terminated to notify affected beneficiaries that it is no longer a contract supplier no later than 15 days prior to the effective date of termination.

Hearing Aid Coverage. The final rule codifies current Medicare Benefit Policy Manual provisions regarding hearing aids that can be considered a prosthetic device and not subject to the statutory exclusion of hearing aids from Medicare coverage. CMS did not adopt its policy to exclude auditory osseointegrated implant (AOI) devices from coverage.

Minimal Self-Adjustment of Orthotics. CMS had proposed to clarify the “specialized training” that is needed to provide custom fitting services for orthotics if providers are not certified orthotists. The proposal would have limited those individual considered to have specialized training to physicians, treating practitioners, occupational therapists, and physical therapists. Orthotics adjusted by other individuals without “specialized training” would be considered off-the-shelf orthotics” (which are subject to the competitive bidding program). In the final rule, CMS did not adopt this proposal.

CMS Publishes Final 2015 ESRD PPS Rule

CMS published its final rule to update the Medicare end-stage renal disease (ESRD) PPS for CY 2015 on November 6, 2014. For CY 2015, the final ESRD PPS base rate is $239.43, which reflects a 0.0 percent update mandated by section 217(b)(2) of PAMA, and the application of a wage index budget-neutrality adjustment factor to the CY 2014 ESRD PPS base rate of $239.02. Nevertheless, CMS estimates that the rule will increase payments to ESRD facilities by approximately $30 million in 2015 due to updates to the outlier threshold amounts. The final rule also, among other things: rebases the ESRD bundled market basket using 2012 data; revises the market basket measures; updates the labor-related share value with a two-year transition; clarifies the eligibility criteria for the low volume payment adjustment; and implements a PAMA provision providing that payment for ESRD-related oral-only drugs will not be made under the ESRD PPS prior to January 1, 2024. CMS also adopted updates to the ESRD Quality Incentive Program (QIP) for payment years 2017 and 2018, including changes to the measure sets and establishment of a new scoring methodology beginning in 2018. Finally, the rule makes significant changes to Medicare reimbursement policy for DME, prosthetics, orthotics, and supplies (DMEPOS), as discussed in a separate post.

Final CY 2015 Medicare Payment Rules in the Pipeline

CMS is expected to publish several major final Medicare payment rules for 2015 in the coming days. The agency has already submitted to the White House Office of Management and Budget (OMB) for regulatory clearance the final 2015 rules updating Medicare payments for outpatient hospitals, ambulatory surgical centers, home health agencies, and end-stage renal disease facilities, along with reimbursement policy updates impacting suppliers of durable medical equipment, prosthetics, orthotics, and supplies. The final Medicare physician fee schedule rule is not yet at OMB, but it should be following shortly. While the text of the regulations are not yet available, we expect that the rules will be put on display at the Federal Register in the near future. We will be providing summaries of the final rules in future updates.

CMS Announces Plans for Medicare DMEPOS Competitive Bidding Round 2 Recompete and National Mail-Order Recompete

On July 15, 2014, the Centers for Medicare & Medicaid Services (CMS) announced its plans to recompete the supplier contracts awarded in Round 2 of the Medicare Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Competitive Bidding Program and the National Mail-Order diabetic testing supplies competition, as it is required by statute to do at least every three years.  The current contract period expires June 30, 2016; the new contracts will begin on July 1, 2016.  For the recompete, CMS is making changes to both the composition of the product categories (including adding new products) and the number of competitive bidding areas (CBAs).

The product categories to be included in the Round 2 Recompete are as follows:

  • Enteral Nutrients, Equipment and Supplies
  • General Home Equipment and Related Supplies and Accessories
    • includes hospital beds and related accessories, group 1 and 2 support surfaces, commode chairs, patient lifts, and seat lifts
  • Nebulizers and Related Supplies
  • Negative Pressure Wound Therapy (NPWT) Pumps and Related Supplies and Accessories
  • Respiratory Equipment and Related Supplies and Accessories
    • includes oxygen, oxygen equipment, and supplies; continuous positive airway pressure (CPAP) devices and respiratory assist devices (RADs) and related supplies and accessories
  • Standard Mobility Equipment and Related Accessories
    • includes walkers, standard power and manual wheelchairs, scooters, and related accessories
  • Transcutaneous Electrical Nerve Stimulation (TENS) Devices and Supplies

This configuration reflects the following changes:  the current Oxygen and CPAP Devices/Respiratory Assist Devices product categories were combined into a single product category; the current Walkers and Wheelchairs/Scooters categories were combined into a single product category; a new General Home Equipment category was created, including the previous Hospital Beds and Support Surfaces categories in addition to new products; and a new TENS devices product category was added.  Suppliers can bid on one or more product categories, but they must bid on all specified HCPCS codes within the category.  A list of the specific items in each product category is available on the Competitive Bidding Implementation Contractor (CBIC) website.

 

CMS is conducting the Round 2 Recompete in the same geographic areas that were included in Round 2.  Because of changes to the metropolitan statistical areas and boundary changes to ensure that no CBA is included in more than one state, however, there will be 117 CBAs in the Round 2 Recompete (compared to 100 in the current competition).  A list of the ZIP codes included in each CBA is also available on the CBIC website.

 

CMS will also be conducting the National Mail-Order Recompete for diabetic testing supplies concurrently with the Round 2 Recompete.  The competition will include all parts of the United States, including the 50 states, the District of Columbia, Puerto Rico, the U.S. Virgin Islands, Guam, and American Samoa.

 

CMS has announced the following general timeline for the Round 2 Recompete/National Mail Order Recompete:

 

July 15, 2014

  • CMS begins “pre-bidding supplier awareness program”

Fall 2014

  • CMS announces bidding schedule
  • CMS begins bidder education program
  • Bidder registration period to obtain user ID and passwords begins

Winter 2015

  • Bidding begins

Suppliers considering bidding should prepare now, including ensuring that their enrollment files at the National Supplier Clearinghouse are current, and that they are accredited and hold all necessary state licenses for any products for which they will bid.  For more information about the DMEPOS bidding program, see our previous postings at http://www.healthindustrywashingtonwatch.com/tags/dmepos-competitive-bidding/.

CMS Proposes Major Changes to Medicare DMEPOS Payment/Coverage Policy Inside/Outside of Competitive Bidding Areas

On July 2, 2014, the Centers for Medicare & Medicaid Services (CMS) released a proposed rule that would make a series of significant changes to Medicare coverage and payment policies for durable medical equipment (DME), prosthetics, orthotics, and supplies (DMEPOS). Notably, the proposed rule would establish a methodology for adjusting Medicare DMEPOS fee schedule payment amounts across the country using information from the Medicare DMEPOS Competitive Bidding Program (CBP) – which CMS estimates would cut Medicare DMEPOS reimbursement by more than $7 billion in FYs 2016 through 2020. The proposed rule also would: test the use of bundled monthly payment amounts for DME and enteral nutrition under the CBP; modify CBP change of ownership (CHOW) and termination of contract rules; clarify qualifications for providing custom fitting services for orthotics; and revise Medicare hearing aid coverage policy. These provisions, which were part of a broader proposed rule that would also update the Medicare end-stage renal disease prospective payment system for 2015, are summarized in our Client Alert.

OIG Reports Assess Impact of Mail-Order Competitive Bidding on Diabetes Test Strips Market Concentration

The OIG has issued two reports on Medicare market share of mail-order diabetes test strips – one examining the market share before the start of Medicare mail-order competitive bidding in July 1, 2013 and a second report examining the three-month period after competitive bidding went into effect. By way of background, the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA) prohibited CMS from awarding competitive bidding program contracts for mail order diabetes test strips to suppliers that do not demonstrate that their bid covers at least 50%, by volume, of all types of mail order diabetes test strips. MIPPA also requires the OIG to complete a study to determine market shares of diabetes test strips in the competitive bidding program.

In a report entitled “Medicare Market Shares of Mail Order Diabetes Test Strips Immediately Prior to the National Mail Order Program,” the OIG provides a baseline for the 3-month period of April to June 2013. Based on a sample of 1,210 claims, the OIG concluded that 152 suppliers submitted at least 62 types of mail order diabetes test strips during this period, with two types of diabetes test strips accounting for approximately 34% of the Medicare mail order market share, four types accounting for 51%, and 10 types accounting for 75%.

In a second report, “Medicare Market Share of Mail Order Diabetes Test Strips from July–September 2013,” the OIG examined a sample of 1,210 Medicare claims in the first three-months of mail-order competitive bidding. According to the OIG, 22 suppliers submitted at least 43 types of mail order diabetes test strips in this period, but two types of diabetes test strips accounted for approximately 45% of the Medicare mail order market share, three types of diabetes test strips accounted for 59% of the market share, and 10 types accounted for 90%. The OIG did not make recommendations in the report, but noted that CMS may choose to consider these data when determining whether subsequent rounds of suppliers’ mail order diabetes test strip bids comply with the MIPPA 50% requirement.

CMS Proposes Medicare Prior Authorization Process for DMEPOS Subject to "Unnecessary Utilization"

CMS has just released a proposed rule that would require Medicare prior authorization (PA) for certain Medicare Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) items that the agency characterizes as “frequently subject to unnecessary utilization.“ As part of the rulemaking, CMS has developed a “Master List” of initial items that it considers to meet this standard based on being (1) identified in a GAO or HHS OIG national report published in 2007 or later as having a high rate of fraud or unnecessary utilization; or (2) listed in the 2011 or later Comprehensive Error Rate Testing (CERT) program's Annual Medicare FFS Improper Payment Rate Report DME Service Specific Overpayment Rate Appendix. CMS also proposes limiting the items on the Master List to those with an average purchase fee of at least $1,000 or an average rental fee schedule of at least $100 to allow CMS to focus on items with the largest potential savings for the Medicare Trust Fund. CMS proposes that the Master List will be “self-updating” annually, and that items generally will remain on the list for 10 years. Note, however, that presence on the Master List would not automatically require prior authorization. CMS would limit the PA requirement to a subset of items (called the “Required Prior Authorization List") “to balance minimizing provider and supplier burden with our need to protect the Trust Funds." CMS would publish the Required Prior Authorization List in the Federal Register with 60-day notice before implementation. CMS also proposes that the PA program could be implemented nationally or locally. The proposed rule does not announce the first items on the Required Prior Authorization List. Instead, CMS is seeking public comment on the number of items that should be selected initially and in the future, and the frequency with which CMS should select items.

The proposed PA process would not create new clinical documentation requirements for the selected DMEPOS items. Instead, the same information necessary now to support Medicare payment for the item would be submitted to the contractor, but before the item could be furnished to the beneficiary and before the claim could be submitted for payment. Upon receipt of a PA request, CMS or its contractors would determine whether the item complies with applicable coverage, coding, and payment rules, and then communicate a decision that provisionally affirms or non-affirms the request. CMS or its contractors would “make reasonable efforts” to provide a decision within 10 days of receipt of all applicable information, unless this timeline could “seriously jeopardize the life or health of the beneficiary,” in which case the target review period would be 2 business days.

The proposed rule also discusses, among other things: the process for updating the Master List; liability for an item on the Required Prior Authorization List if authorization is submitted and denied, the opportunity for unlimited PA resubmissions, and applicability to competitive bidding areas. The rule also would add a contractor's decision regarding prior authorization of coverage of DMEPOS items to the list of actions that are not initial determinations and therefore not appealable.  The official version will be published on May 28, 2014. CMS will accept comments on the proposed rule until July 28, 2014.

In a related development, CMS has announced that it is expanding its current demonstration for prior authorization for power mobility devices to 12 additional states. CMS also will launch two payment model demonstrations to test prior authorization for hyperbaric oxygen therapy and repetitive scheduled non-emergent ambulance transport; information from these models will inform future CMS policy decisions on the use of prior authorization.

OIG, GAO Reports Examine Round 1 Rebid of the Medicare DMEPOS Competitive Bidding Program

On April 8, 2014, the OIG and GAO each issued reports focusing on different aspects of the “Round 1 Rebid” of the Medicare durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) competitive bidding program. By way of background, under DMEPOS competitive bidding, only suppliers that are winning bidders, meet licensing and other standards, and enter into a contract with CMS may furnish selected categories of DMEPOS to Medicare beneficiaries in competitive bidding areas (CBAs), with very limited exceptions. Contract suppliers are paid based on the median of the winning suppliers’ bids in the CBA, rather than the DMEPOS fee schedule amount. The Round 1 Rebid was in effect for a 3-year period, from 2011 through 2013, involving nine DME product categories in nine CBAs. CMS subsequently “recompeted” contracts in the Round 1 areas (including additional products), with three-year contracts effective January 1, 2014. CMS also established a second round of bidding covering 100 CBAs, along with a national mail-order diabetic testing supplies competitive bidding program; those three-year contracts went into effect July 1, 2013.

The OIG report assesses CMS compliance with DMEPOS bidding rules in the Round 1 Rebid. The OIG concluded that CMS generally followed its competitive bidding program rules when it selected suppliers and computed single payment amounts for the Round 1 Rebid – although a number of CMS errors were identified. Specifically, the OIG conducted a review based on a random sample of 100 of the 3,011 established DMEPOS single payment amounts in the Round 1 Rebid Program and the selection process for 266 winning suppliers associated with the sampled payment amounts. The OIG determined that CMS followed all applicable requirements for 255 of the 266 winning suppliers, but nine winning suppliers did not meet financial documentation requirements, and CMS incorrectly used two suppliers in one single payment computation. While the OIG characterizes the overall effect on Medicare payments to suppliers as “immaterial,” the OIG estimates that CMS paid suppliers $34,000 less than they would have received without any errors (less than 0.1 percent of the $113 million paid under the Round 1 Rebid Program during the first 6 months of 2011). The OIG recommends that CMS: (1) follow its established program procedures and applicable federal requirements consistently in evaluating the financial documents of all suppliers, and (2) ensure that all bids of winning suppliers are included in the calculation of single payment amounts before offering contracts. CMS concurred with the recommendations, and pointed out that it has enhanced the financial review process to ensure that all reviewers are accountants or certified public accountants.  Looking ahead, the OIG will be conducting a similar analysis for Round 2 of competitive bidding; this analysis may include an analysis of CMS’s procedures for ensuring supplier compliance with applicable state licensure requirements (depending on the results of an ongoing limited scope review).

The GAO issued a broader review focusing on data from the second year of the Round 1 Rebid contracts, covering the Round 1 Rebid’s effects on Medicare beneficiaries, contract suppliers, and non-contract suppliers. Among other things, the GAO observed that:

  • The number of beneficiaries furnished DME items included in the competitive bidding program generally decreased more in CBAs than in demographically similar “comparator” areas. CMS suggests that such declines may be attributable to reduced inappropriate usage of DME and do not necessarily reflect beneficiary access issues. In fact, CMS stated in comments on the report that its “sophisticated real-time claims monitoring system has continuously found that beneficiary access to all necessary and appropriate competitive bid items has been preserved since the program began” – a conclusion generally disputed by industry.
  • A small number of contract suppliers generally had a large proportion of the market share in the nine competitive bidding areas.
  • The total number of DME suppliers and Medicare allowed charges decreased more in CBAs than in the comparator areas. For instance, the number of suppliers with Medicare allowed charge amounts of $2,500 or more per quarter decreased an average of 27% in the CBAs compared to 5% in the comparator areas.
  • The number of grandfathered suppliers had so diminished that CMS was no longer monitoring them after the second quarter of 2012.
  • The program did not appear to have adversely affected beneficiary access to covered items, although additional monitoring would be needed to monitor the impact of the national mail-order diabetic testing supplies program and Round 2.

CMS Takes First Steps to Cut Medicare DMEPOS Fees Based on Competitive Bidding Prices

On February 26, 2014, CMS published an advance notice of proposed rulemaking (ANPRM) seeking public comments on two potential changes to Medicare reimbursement for durable medical equipment (DME), prosthetics, orthotics, and supplies (DMEPOS) that could impact payment to DMEPOS suppliers nationwide regardless of whether they participate in competitive bidding. At this point, CMS is providing more questions than answers on the future of Medicare DMEPOS reimbursement policy, as discussed below.

First, CMS is requesting comments on how to implement a statutory requirement that it use pricing information from the DMEPOS competitive bidding program to adjust Medicare payments for DMEPOS items and services furnished outside of competitive bidding areas (CBAs). By way of background, the Affordable Care Act (ACA) requires CMS to use information from the DMEPOS competitive bidding program to adjust DME fee schedule amounts in areas where competitive bidding programs are not implemented by January 1, 2016; CMS also is authorized (but not mandated) to make such adjustments for off-the-shelf orthotics and enteral nutrients, supplies, and equipment in areas where competitive bidding programs have not been established. CMS must promulgate its methodology for making such adjustments through notice and comment rulemaking, and it must consider costs outside of CBAs compared to rates in CBAs.

Prior to issuing a proposed methodology for adjusting payments in non-CBAs, CMS is soliciting public comments on a number of aspects of this policy, including the following:

  • Do the costs of furnishing DMEPOS items and services vary based on the geographic area in which they are furnished, and if so, how should the methodology account for these geographic variations?
  • Do the costs of furnishing DMEPOS items and services vary based on population size, distance covered, or other logistical or demographic factors?
  • How should CMS adjust payments for items that have not been included in all competitive bidding programs (such as transcutaneous electrical nerve stimulation (TENS) devices that have only been included in nine Round 1 areas so far)?
  • Should competitive bidding programs be established in all areas of the country for a few high-volume items to gather general cost information (e.g., rural vs. urban area costs)?
  • What factors should be used to determining a competitive service area in rural areas?

In addition to seeking comments related to adjustments of DMEPOS payments outside of CBAs, CMS is considering potential modifications to its competitive bidding payment policy to allow the use of bundled payments for certain types of DME and enteral nutrition. Under this concept, which would require future rulemaking, suppliers would submit one bid that reflects the average per beneficiary monthly cost of furnishing the DME, supplies, and accessories along with the maintenance and servicing costs. CMS would make monthly payments to the supplier for as long as the equipment were medical necessary; that is, rental payments would no longer reach a cap, but at the same time, CMS would no longer make separate payment for supplies, accessories, enteral nutrients, or maintenance and servicing. The supplier would retain title to the equipment. Whether CMS proceeds with proposing this change depends on issues such as administrative burden and feasibility, as well as other potential issues raised in public comments. CMS states that it is particularly interested in feedback on issues such as:

  • Are lump sum purchases and capped rental payment rules for DME and enteral nutrition equipment still needed if monthly payment amounts can be established under competitive bidding?
  • Are there reasons that beneficiaries need to own expensive DME or enteral nutrition equipment rather than use such equipment as needed on a continuous monthly basis?
  • What would be the advantages and disadvantages to beneficiaries and suppliers associated with such a bundled approach?
  • Would bundled monthly payment adversely impact beneficiary access to personalized items such as speech generating devices and specialized wheelchairs?
  • If CMS maintains payment on a capped rental, rent-to-own basis or lump sum purchase basis, should CMS require that the supplier that transfers the equipment title to the beneficiary be responsible for all maintenance and servicing of the beneficiary-owned equipment for the remainder of the equipment's reasonable useful lifetime with no additional payment? The associated costs ostensibly would be factored into bids and payment amounts.
  • Would payment on a bundled, continuous rental basis adversely impact the beneficiary's ability to direct their own care, follow a provider’s plan of care, or provide for appropriate care transitions?

Comments are due to CMS by March 28, 2014. Interested parties will have another opportunity to comment on these provisions when the proposed regulations are issued.

CMS Adopts Changes to Medicare Payment, Coverage Rules for DMEPOS

As part of the CY 2014 Medicare end stage renal disease (ESRD) prospective payment system (PPS) final rule, published on December 2, 2013, CMS has adopted updates to three Medicare durable medical equipment (DME), prosthetics, orthotics, and supplies (DMEPOS) policies.

  • 3-Year Minimum Lifetime Requirement (MLR). CMS previously issued regulations providing that, effective for items classified as DME after January 1, 2012, the item must have an expected life of at least 3 years to be considered “durable.” The final ESRD PPS rule clarifies the treatment of a “grandfathered item” classified as DME on or before January 1, 2012 if that product is subsequently modified (e.g., upgraded, refined, or reengineered). Specifically, effective April 1, 2014, if a grandfathered product is modified, and the modified product has an expected life that is shorter than that of the original product, the modified item will lose its grandfathered status and it will be subject to the 3-year MLR requirement. The impact of the loss of grandfathered status on coverage would depend on the new expected lifetime of the modified product. For instance, if a grandfathered product covered as DME prior to 2012 with a lifetime of four years is modified, resulting in a product with a lifetime of 2.5 years, this product would lose its grandfathered status and no longer meet the definition of DME because the 3-year MLR would not be met. On the other hand, if this modification reduced the lifetime of the product to 3.5 years, the product would lose its grandfathering status but would satisfy the 3-year rule and continue to meet the definition of DME.
  • Reclassification of Routinely-Purchased DME. The final clarifies the definition of routinely purchased equipment at §414.220(a)(2) to address inconsistencies in how CMS has classified certain expensive items as routinely purchased, rather than capped rental. CMS adopted its proposal to reclassify as capped rental items about 80 DME and DME accessory HCPCS codes added after 1989 that are currently classified as routinely purchased (although CMS agreed with commenters that E0760, Osteogenesis Ultrasound Stimulator, should remain classified as routinely purchased equipment). The complete list of codes subject to this provision is set forth in Table 11. The effective dates for the reclassifications are: (1) April 1, 2014, for items not included in DMEPOS competitive bidding (which is 3 months later than CMS initially proposed); (2) July 1, 2016, for (a) items furnished in all areas of the country if the item is included in a Round 2 competitive bidding program (CBP) and not in a Round 1 Recompete CBP, and (b) for items included in a Round 1 Recompete CBP but furnished in an area other than one of the nine Round 1 Recompete areas; and (3) January 1, 2017, for items included in a Round 1 Recompete CBP and furnished in one of the nine Round 1 Recompete areas. 
  • Fee Schedules for Splints, Casts, and Certain IOLs. CMS has adopted its proposal to implement on a budget-neutral basis Medicare fee schedules for splints and casts, and intraocular lenses (IOLs) inserted in a physician’s office. This provision is effective for services furnished on or after April 1, 2014. In future years, the fee schedule amounts will be updated by the percentage increase in the CPI-U for the 12-month period ending with June of the preceding year, reduced by the multifactor productivity adjustment.

CMS also has adopted certain technical amendments to DMEPOS payment regulations.

CMS Announces Medicare DMEPOS Bidding Round 1 Recompete Contract Suppliers

CMS has announced the names of 282 suppliers that have been awarded 3-year contracts under the Medicare DME, prosthetics, orthotics, and supplies (DMEPOS) competitive bidding program “Round 1 Recompete.” As discussed in our previous reports, this phase of bidding applies to nine geographic areas where competitive bidding contracts have been in effect since 2011, but it includes a broader array of products than currently covered. The contract period for the Round 1 Recompete is January 1, 2014 through December 31, 2016.

By way of background, under DMEPOS competitive bidding, only suppliers that are winning bidders, meet licensing and other standards, and enter into a contract with CMS may furnish selected categories of DMEPOS to Medicare beneficiaries in competitive bidding areas (CBAs), with very limited exceptions. Contract suppliers are paid based on the median of the winning suppliers’ bids in the CBA, rather than the DMEPOS fee schedule amount. CMS reported earlier this year that Medicare reimbursement will be cut by an average of 37% compared to fee schedule amounts under the Round 1 Recompete contracts, which include the following six product categories: (1) Respiratory Equipment and Related Supplies and Accessories (includes oxygen, oxygen equipment, and supplies; continuous positive airway pressure devices and respiratory assist devices, and related supplies and accessories; and standard nebulizers); (2) Standard Mobility Equipment and Related Accessories (includes walkers, standard power and manual wheelchairs, scooters, and related accessories); (3) General Home Equipment and Related Supplies and Accessories (includes hospital beds and related accessories, group 1 and 2 support surfaces, transcutaneous electrical nerve stimulation devices (TENS), commode chairs, patient lifts, and seat lifts); (4) Enteral Nutrients, Equipment and Supplies; (5) Negative Pressure Wound Therapy Pumps and Related Supplies and Accessories; and (6) External Infusion Pumps and Supplies.

CMS reports that Round 1 Recompete contract suppliers have 620 locations to serve Medicare beneficiaries in the CBAs, and about 58% of these suppliers are “small suppliers” with gross revenues of $3.5 million or less. CMS will now accelerate educational efforts aimed at suppliers, referral agents, and beneficiaries in preparation for the new contracts.

Medicare Rates to Fall by Average of 37% under DMEPOS Competitive Bidding "Round 1 Recompete" Contracts

CMS has announced the contract prices for items included in the Medicare durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) competitive bidding “Round 1 Recompete.”  As discussed in our previous reports, this phase of bidding applies to nine geographic areas where competitive bidding has been in effect since 2011, but it includes a broader array of products. The contract period for the Round 1 Recompete is January 1, 2014 through December 31, 2016.

Contract prices under the Round 1 Recompete will average 37% below Medicare's fee schedule rates for the six product categories, according to files posted by the Competitive Bidding Implementation Contractor (CBIC) on October 1, 2013. The weighted average savings by product category are as follows:

Enteral Nutrients, Equipment & Supplies

External Infusion Pumps & Supplies

General Home Equipment and Related Supplies & Accessories

NPWT Pumps and Related Supplies & Accessories

Respiratory Equipment and Related Supplies & Accessories

Standard Mobility Equipment & Related Accessories

Overall Average

41%

21%

47%

42%

40%

34%

37%

These savings compare to a 45% average cut for suppliers participating in Round 2 of the competitive bidding program and a 72% reduction under the national mail order competition for diabetic testing supplies; contracts for both of these programs went into effect July 1, 2013.

The CBIC also posted statistics on the number of Round 1 Recompete contract offers extended for each competitive bidding area (CBA) and product category and the number of supplier locations represented in those offers.  The contracting process for the Round 1 Recompete is now underway. Bidders who were not “winners” will be notified of the reasons they were not offered contracts. CMS plans to announce the names of contract suppliers this fall.

OIG Focuses on Improper Medicare Diabetes Test Strip Payments

A recent OIG report examines the extent of improper Medicare reimbursement for diabetes test strips (DTS), including the effect of mail-order DTS being subject to competitive bidding in nine geographic areas beginning in 2011 (CMS subsequently implemented a national competitive bidding program for mail-order DTS, effective July 1, 2013). According to the OIG, in 2011, Medicare inappropriately allowed $6 million for DTS claims billed for beneficiaries without a documented diagnosis code for diabetes, or that inappropriately overlapped with an inpatient hospital stay or an inpatient skilled nursing facility stay. Moreover, the OIG identified $425 million in Medicare-allowed DTS claims in 2011 that had characteristics of questionable billing, such as claims in excess of utilization guidelines, claims at perfectly regular intervals, or overlapping claims for the same beneficiary. The OIG observes that the Medicare competitive bidding program appears to have been successful in reducing questionable billing for mail-order DTS, since Medicare allowed claims for mail order DTS for suppliers exhibiting questionable billing in CBAs fell from $33.2 million to $4.3 million between 2010 and 2011. The OIG recommended that CMS take additional action to address inappropriate DTS claims, such as expanding supplier education, enforcing claims edits, and increasing monitoring of DTS suppliers’ billing. CMS also agreed to take appropriate action regarding inappropriate Medicare DTS claims and suppliers identified by the OIG, including referral of questionable claims to the Recovery Auditors and Medicare Administrative Contractors (MACs).

OIG Reports Point States to Potential Medicaid DMEPOS Savings

Two recent OIG reports point out the savings that state Medicaid programs could attain if they based reimbursement for DME, prosthetics, orthotics, and supplies (DMEPOS) on Medicare competitive bidding payment amounts – although at least one state is pushing back on this idea. In the first report, “Medicaid DMEPOS Costs May be Exceeding Medicare Costs in Competitive Bidding Areas,” the OIG calculated the potential savings Texas could have achieved in 2011 if it adopted Medicare DMEPOS bidding prices for selected items of DMEPOS. According to the OIG, Texas Medicaid fee-schedule could have saved approximately $2 million (state/federal shares combined) in the Dallas/Fort Worth area if it had based Medicaid rates on the Medicare DMEPOS competitive bidding amounts for 32 DMEPOS items covered under both programs. The OIG states that its report provides “a tangible example of potential State and Federal savings for Medicaid programs if the programs were to use the Medicare Competitive Bidding payment amounts for DMEPOS items.” This report did not include recommendations or state reaction. 

In the second report, “New Jersey Medicaid Program Could Achieve Savings by Reducing Home Blood-Glucose Test Strip Prices,” the OIG estimates that the New Jersey Medicaid program could have saved approximately $1.8 million to $2.7 million in 2011 by reducing home blood-glucose test strip reimbursement rates to retail rates or by establishing a competitive bidding program for test strips. Such policy changes for test strips also could reduce Medicaid managed care organization reimbursement rates by up to 70%. However, the New Jersey Department of Human Services disagreed with the OIG’s recommendations to align state Medicaid reimbursement with average retail price or Medicare competitive bidding pricing, citing, among other things, doubts about the feasibility of attaining such savings and concerns about patient access and the impact on proper diabetes management.

CMS Updates Off-The-Shelf (OTS) Orthotics Listing for 2014

CMS has updated its list of Healthcare Common Procedures Coding System Codes (HCPCS) codes that it considers to be off-the-shelf (OTS) orthotics – and therefore subject to inclusion in a future round of the DMEPOS competitive bidding program. Under the Social Security Act, OTS orthotics are those that require minimal self-adjustment for appropriate use and do not require expertise in trimming, bending, molding, assembling, or customizing to fit to the individual. CMS has defined "minimal self-adjustment" to mean an adjustment that the beneficiary, caretaker for the beneficiary, or supplier of the device can perform and that does not require the services of a certified orthotist or an individual who has specialized training. The statute authorizes CMS to included OTS orthotics in DMEPOS competitive bidding, although CMS has not included these items in the competitions announced to date. CMS notes that while it has not determined the schedule for bidding OTS orthotics, it will identify the specific OTS orthotic codes included in a competitive bidding program through program instructions or website posting. The 2014 listing, which was posted on August 12, 2013, revises a preliminary listing CMS released in February 2012. CMS also responds to public comments it received on the 2012 listing. CMS expects to make subsequent coding updates to the OTS list through program instructions.

CMS Announces "Winners" of Medicare DMEPOS Competitive Bidding Round 2/National Mail Order Competition

On April 9, 2013, CMS announced the names of 799 suppliers that have been awarded 3-year contracts under Round 2 of the Medicare durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) competitive bidding program, along with the 18 suppliers that accepted contracts under the national mail order competition for diabetic testing supplies. Under competitive bidding, only suppliers that are winning bidders, meet licensing and other standards, and enter into a contract with CMS may furnish selected categories of DMEPOS to Medicare beneficiaries in competitive bidding areas (CBAs), with very limited exceptions. Winning bidders who sign contracts are paid based on the median of the winning suppliers’ bids in the CBA, rather than the DMEPOS fee schedule amount. Contracts under Round 2 and national mail-order contracts begin on July 1, 2013. As previously reported, Medicare reimbursement will be cut by an average of 45% for suppliers participating in Round 2, which covers eight product areas in 100 CBAs. Mail-order diabetic testing supplies contracts cover all 50 States, the District of Columbia, Puerto Rico, the U.S. Virgin Islands, Guam, and American Samoa. Medicare reimbursement for diabetic testing supplies will fall 72% compared to current fee schedule amounts (the new prices will be applied in the retail setting as well under separate legislative authority). CMS notes that Round 2 contract suppliers have 2,988 locations to serve Medicare beneficiaries in the CBAs, and about 63% of these suppliers are “small suppliers,” with gross revenues of $3.5 million or less. CMS will now step up educational efforts aimed at suppliers, referral agents, and beneficiaries in preparation for the expansion of competitive bidding this summer.

CMS Requests Comments on New Forms to Disclose Competitive Bidding Contract Supplier Ownership Changes

CMS is seeking comments on new forms it intends to require suppliers to use to report changes of ownership (CHOW) involving contract suppliers under the Medicare durable medical equipment, prosthetics, orthotics and supplies (DMEPOS) competitive bidding program. CMS will evaluate the information in the forms to determine if a supplier that merges with or acquires a contract supplier meets the conditions for awarding a competitive bidding contract as specified in regulations. The proposed Change of Ownership Purchaser Form and Contract Supplier Notification Form will be used in all rounds of competition. CMS will accept comments on the forms through April 30, 2013.

Older Entries

March 13, 2013 — CMS Plans to Include DME Infusion Drugs in Competitive Bidding in Response to OIG Findings

January 31, 2013 — CMS Slashes Medicare Reimbursement under Round 2 of the Medicare DMEPOS Competitive Bidding Program/National Mail Order Competition for Diabetic Testing Supplies

January 14, 2013 — OIG Calls for Cuts in Medicare Rates for Back Orthoses

January 14, 2013 — OIG Finds DMEPOS Competitive Bidding Not Spurring Suppliers to Solicit Specific Brands/Modes of Delivery

January 4, 2013 — Fiscal Cliff Deal Includes Medicare Cuts and Other Health Policy Changes

November 14, 2012 — OIG Reviews Impact of DMEPOS Bidding Program on Billing for Diabetes Test Strips (DTS)

October 16, 2012 — CMS Accepting Bids for the Round 1 Recompete of the DMEPOS Competitive Bidding Program

September 27, 2012 — Congressional Health Policy Hearings

September 5, 2012 — Congressional Hearings

August 17, 2012 — CMS Announces Timeline for Medicare DMEPOS Competitive Bidding Round 1 Recompete

June 26, 2012 — CMS Officially Announces Potential Inherent Reasonableness Payment Adjustment for Medicare Retail Diabetic Testing Supplies; Meeting Set for July 23

May 23, 2012 — CMS Examining Inherent Reasonableness Payment Adjustment for Medicare Retail Diabetic Testing Supplies; Meeting Scheduled for July 23

May 14, 2012 — Congressional Health Policy Hearings

April 23, 2012 — DMEPOS Bidding "Recompete" Subjects New Products to Competitive Bidding, Expands Product Categories

March 12, 2012 — CMS Finalizes Revisions to Medicare DMEPOS Supplier Standards

February 28, 2012 — CMS Updates Data on DMEPOS Competitive Bidding Program Health Outcomes

February 13, 2012 — DMEPOS Competitive Bidding Open, State Licensure Deadline Extended

February 13, 2012 — CMS Seeks Comments on List of Off-the-Shelf Orthotics Codes

December 9, 2011 — CMS Launches Round 2 of DMEPOS Competitive Bidding Program; Registration Underway

November 14, 2011 — CMS Transmittal on 2012 Update to DMEPOS Fee Schedule

October 14, 2011 — Updated Resources for DMEPOS Competitive Bidding

September 30, 2011 — MedPAC Offers Medicare SGR Proposal, With Offsetting Medicare Cuts

September 1, 2011 — Preparing for Round 2 of the DMEPOS Competitive Bidding Program

August 19, 2011 — CMS Announces Products for Round 2 DMEPOS Competitive Bidding Program

July 18, 2011 — CMS Releases Data on Health Status Under DMEPOS Competitive Bidding

July 18, 2011 — GAO Examines Potential "Manufacturer-Level" DMEPOS Competitive Bidding.

April 13, 2011 — CMS Proposes Additional Changes to DMEPOS Supplier Standards

April 13, 2011 — CMS Delays Second Round of DMEPOS Competitive Bidding; Provides Update on Round 1 Rebid.

March 29, 2011 — DMEPOS Competitive Bidding "Form C" Deadline Delayed

March 7, 2011 — DMEPOS Bidding Documentation, Quarterly Reporting Requirements, FAQs on Supplier Standards

March 2, 2011 — CMS Schedules April 5, 2011 DMEPOS Competitive Bidding PAOC Meeting

December 15, 2010 — OIG Report on Mail Order Diabetic Testing Strips

November 27, 2010 — DMEPOS Competitive Bidding Meeting/San Bernardino, CA (Dec. 7)

November 16, 2010 — CMS Issues Final CY 2011 Physician Fee Schedule Rule

November 15, 2010 — DMEPOS Bidding Contractors Announced

November 1, 2010 — Medicare DMEPOS Competitive Bidding Educational Calls (Nov. 8 & 16)

October 29, 2010 — DMEPOS Competitive Bidding Update

September 17, 2010 — September 2010 Congressional Hearings

September 9, 2010 — Upcoming Congressional Hearing on DMEPOS Competitive Bidding (Sept. 15)

August 13, 2010 — DMEPOS Competitive Bidding Educational Articles

July 12, 2010 — CMS Issues Proposed CY 2011 Physician Fee Schedule Update

July 10, 2010 — DMEPOS Competitive Bidding Prices Released

July 8, 2010 — Reed Smith Health Care Reform Review: The Affordable Care Act - Analysis and Implications for DMEPOS Suppliers

May 13, 2010 — CMS Materials on DMEPOS Competitive Bidding Program

March 30, 2010 — PAOC Meeting/Timeline for Round 2 of DMEPOS Competitive Bidding Program

February 18, 2010 — PAOC Meeting on DMEPOS Competitive Bidding Postponed to March 17

February 4, 2010 — DMEPOS Bidding PAOC Meeting Agenda, Educational Materials Posted

January 20, 2010 — DMEPOS Competitive Bidding/PAOC Meeting (Feb. 23, 2010)

January 13, 2010 — Enteral Nutrient Prices During Non-Part A Nursing Stays

December 21, 2009 — GAO Highlights Problems in First Round of DMEPOS Competitive Bidding

November 11, 2009 — Final CY 2010 Medicare Physician Fee Schedule Rule Released

October 30, 2009 — DMEPOS Competitive Bidding Window Open until December 21, 2009

October 15, 2009 — DMEPOS Accreditation Delay for Pharmacies

October 15, 2009 — DMEPOS Competitive Bidding Update

September 17, 2009 — DMEPOS Bidding Financial Documentation Requirements - CMS Call on Sept. 22, 2009

August 27, 2009 — CMS Call on DMEPOS Competitive Bidding - Rules for Bidding Successfully (Sept. 2, 2009)

August 17, 2009 — DMEPOS Competitive Bidding Registration Period Opens

August 15, 2009 — Schedule of Medicare DMEPOS Competitive Bidding Supplier Education Events

August 7, 2009 — Medicare DMEPOS Bidding Education Calls, Materials

August 3, 2009 — CMS Announces Detailed DMEPOS Competitive Bidding Timeline

July 27, 2009 — Preparing for DMEPOS Competitive Bidding

July 16, 2009 — CMS DMEPOS Bidding Program "Webinar" -- July 20, 2009

July 7, 2009 — CMS Proposes CY 2010 Medicare Physician Fee Schedule Rule

June 5, 2009 — CMS Targets January 2011 Implementation Date for DMEPOS Competitive Bidding

May 29, 2009 — CMS Announces General Timeline for DMEPOS Competitive Bidding Program

May 21, 2009 — CMS Releases Draft DMEPOS Competitive Bidding Forms

May 14, 2009 — CMS Prepares to Re-Launch Medicare DMEPOS Competitive Bidding -- Tips for Potential Bidders

May 8, 2009 — PAOC Meeting on DMEPOS Competitive Bidding Program -- June 4, 2009

April 24, 2009 — DMEPOS Competitive Bidding

April 6, 2009 — Negative Pressure Wound Therapy (NPWT) Pumps

March 6, 2009 — DMEPOS Competitive Bidding Rule Delay

February 19, 2009 — MIPPA DMEPOS Bidding Rule Effective Date Delayed

February 12, 2009 — Congressional Hearings

February 9, 2009 — Comment Opportunity on MIPPA DMEPOS Competitive Bidding Rule (Due Feb. 12, 2009)

January 27, 2009 — DMEPOS Competitive Bidding

December 1, 2008 — 2009 Medicare DMEPOS Fee Schedule Released

October 7, 2008 — Medicare DMEPOS Competitive Bidding Advisory Committee Member Solicitation

August 22, 2008 — DMEPOS Accreditation

July 29, 2008 — Medicare Physician Payment/DMEPOS Bidding Delay Legislation Enacted

July 29, 2008 — CMS Guidance on MIPPA Implementation.

July 29, 2008 — OIG Guidance on MIPPA/Waiver of Copayments

July 16, 2008 — MIPPA: Medicare Physician Payment/DMEPOS Bidding Delay Legislation Enacted

July 9, 2008 — DMEPOS Competitive Bidding Program

June 20, 2008 — DMEPOS Competitive Bidding Delay Legislation Introduced

June 4, 2008 — DMEPOS Competitive Bidding/PAOC Meeting

June 3, 2008 — DMEPOS Competitive Bidding Developments