A Quote to Remember

"If you are not accredited by Sept. 30, 2009, the National Suppliers Clearinghouse will revoke your billing privileges," said CMS official Sandra Bastinelli.

CMS Sets Accreditation Deadline for Medicare Part B Suppliers

The Centers for Medicare & Medicaid Services (CMS) has set September 30, 2009 as the deadline for Medicare Part B suppliers to attain accreditation in order to provide DMEPOS products and services to beneficiaries. After this date, accreditation will be required in order to apply and receive a Medicare Part B billing number from the National Supplier Clearinghouse.
For more information on accreditation, visit www.pharmacistelink.com/medicaredme

CMS to Announce DMEPOS Accreditation Deadlines

The Centers for Medicare & Medicaid Services will host an Open Door Forum on DMEPOS Accreditation Deadlines Wednesday, Dec. 19, from 2 to 3:30 p.m.

CMS will announce the following during the Forum:

• The deadline by which new suppliers must apply to the National Supplier Clearinghouse (NSC) for a supplier number in order to qualify for a special accreditation grace period;



• The deadline by which new DMEPOS suppliers who qualified for the accreditation grace period will need to be accredited; and



• The deadline by which all DMEPOS suppliers will need to be accredited.

To participate, dial: 1-800-837-1935 and use the Reference Conference ID: 27829970.

Note: TTY Communications Relay Services are available for the Hearing Impaired. For TTY services dial 7-1-1 or 1-800-855-2880 and for Internet Relay services click here http://www.consumer.att.com/relay/which/index.html. A Relay Communications Assistant will help.

For more information on DME Accreditation, visit www.pharmacistelink.com/medicaredme.

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CMS Begins DMEPOS Fraud Demonstration Project – Are You a Targeted Supplier?

The Centers for Medicare & Medicaid Services (CMS) instructed the National Supplier Clearinghouse (NSC) to begin the DMEPOS demonstration project on November 1. This demonstration project involves all DMEPOS suppliers located in the following counties:

South Florida – Miami-Dade, Broward and Palm Beach

Southern California – Los Angeles, Orange, Riverside and San Bernardino

Each DMEPOS supplier in the demonstration locales is required to submit a CMS 855S Medicare enrollment application to the NSC within 30 days after the NSC requests such data.

For mdditional information, visit http://www.cms.hhs.gov/MedicareProviderSupEnroll

Watch Out for Medicare Fraud Strike Force

The Medicare Fraud Strike Force is a multi-agency team of investigators that identifies potential fraud cases through real-time analysis of billing data from the Medicare Program Safeguard Contractors and Health Care Information System claims data. It is part of a multi-phase enforcement and regulatory effort to "improve the quality of the industry and reduce the potential for fraud," according to the Department of Justice.

No Rush to Accredit Says CMS's Bastinelli

After release of its supplier quality standards in August 2006, CMS named 11 approved accrediting organizations late last year to enforce them. A merger in January between two of the organizations left 10 accreditors ready to deal with what many had expected to be an accreditation rush in the initial competitive bidding areas.

But, the rush never came. CMS's Sandra Bastinelli, charged with running the accreditation program, announced at an Oct. 11 meeting of the Program Advisory and Oversight Committee that a total 2,200 provider locations across the 10 CBAs had been accredited. About 100 more applications were pending before the Oct. 31 deadline.

National Family Caregivers Month and the Sandwich Generation

November is National Family Caregivers Month, a time when the nation prepares to thank, support, educate, and celebrate its estimated 50 million caregivers.

Many of your customers are part of the "sandwich" generation -- baby boomers caring for aged parents AND teenagers. They have A LOT of stress. Make it your business to recognize them when they come into your pharmacy. They will use a lot of DMEPOS!

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Not Enough Bidders in First Round

CMS suggested in the Final Rule on competitive bidding that approximately 18,000 DMEPOS suppliers serviced the first 10 selected MSAs. Of those, 90 percent would bid, and of those 50 percent, or approximately 8,000, would be winning bidders. At the most recent PAOC meeting it was disclosed that approximately 2,000 suppliers submitted bids. The question of the day is…are 2,000 suppliers sufficient to provide convenient access to required DMEPOS in a timely manner? Stay tuned!

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Four Reasons Pharmacists Are NOT Yet Accredited

Four Reasons Most Pharmacists Are NOT Yet Accredited to Sell DMEPOS

1. Diabetes supplies are exempt from competitive bidding in the first round (However, you STILL must obtain accreditation to sell them.)
2. The mandatory accreditation deadline for ALL suppliers has NOT been announced (see DMe-Alert, Oct. 19).
3. Accreditation costs still remain prohibitive (approximately $8,500).
4. Surety bond requirements will further increase the costs to maintain a Part B supplier billing number.

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You Need a Crystal Ball to Bid on DMEPOS

Suppliers bidding on DMEPOS product categories like walkers must not only account for inflation over a three year period, but must additionally consider the cost of raw commodities used to build these items. For instance, the price of batteries used in power wheelchairs have skyrocketed due to the incredible increases in the cost of lead.

Even the government has a tough time predicting inflation, raw commodity costs (i.e., crude oil) and the long-term affect on our economy, but suppliers must lock in bid prices for THREE years AND be held accountable if unable to meet winning bid obligations…..go figure!

National Competitive Bidding Deadline Tomorrow

Pharmacist that supply DMEPOS and plan to participate in the first round of national competitive bidding must submit their bids by 9 p.m. EST tomorrow, Sept. 25. I know their aren’t many of you out there, but I thought I’d let you know anyway.

I’m Disappointed...

CMS has scheduled the next PAOC meeting right in the middle of the NCPA Annual Convention in Anaheim. I'll be speaking at the Convention about the challenges of accreditation and competitive bidding. Member concerns regarding surety bonds, accreditation costs and the inappropriateness of the CMS small supplier definition need to be discussed…so I’m NOT happy. I’ll make my concerns known to CMS, but I’d rather do it my self!

If you want to attend as a guest the link below is for sign in.

Program Advisory and Oversight Committee (PAOC) Meeting

October 11, 2007

MEETING SITE

Hilton Pikesville Hotel

1726 Reisterstown Road

Baltimore, MD 21208-2984

Phone: 410-653-1100

Fax: 410-415-6231

MEETING TIMES:

October 11, 2007– 8:00 a.m. to 5:00 p.m.

Thank you for agreeing to participate in the Program Advisory and Oversight Committee (PAOC) Meeting, sponsored by the Centers for Medicare & Medicaid Services (CMS). B L Seamon Corporation (BLS), under contract to CMS, is providing administrative and logistical support for the meeting.

Please take a few minutes to review the following information and to visit http://www.blsmeetings.net/H1102 no later than Monday, September 24, 2007, to confirm your participation at the meeting.

Full Steam Ahead for Competitive Bidding

On Tuesday, September 11, President Bush designated Kerry N. Weems as acting CMS administrator.

Also announced was the appointment of Herb Kuhn as deputy CMS administrator. Kuhn has served for nearly a year as acting deputy administrator.

Speaking at the American Association for Homecare's Legislative Conference in June, Kuhn told the group that CMS is moving toward full implementation of competitive bidding and intends to enforce its final rule on the program--mandated by the Medicare Modernization Act of 2003--as it stands.

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My 'Accreditation Corner'

A new feature has been added to the DME Resource Center (www.pharmacistelink.com/medicaredme) entitled "Accreditation Corner."

As you know by now, in order to maintain a Medicare Part B supplier billing number ALL suppliers must obtain accreditation through one of 10 CMS approved accreditation agencies.

Except for those suppliers that are bidding to supply DME in the first 10 competitive bid areas (deadline 10/31/07), CMS has NOT, as yet, determined when the remaining suppliers, including pharmacies must be accredited.

Authored by Harry Lattanzio, president of PRS Pharmacy Services, Accreditation Corner breaks up the quality standards into an easy-to-understand format and provides helpful tips on how to meet the standards.

Read the pieces and use this time to prepare your staff. Remember agency surveyors won’t just be looking for a manual, but for clear indicators that your business practices executed daily protect the beneficiary and limit fraud.

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Poorly Completed Applications Slow Independents' Accreditation

Some accreditors have voiced their concerns over the lack of attention placed on correctly filling out the agecy's application. In particular, agency customer service representatives are spending an inordinate amount of time trying to sort through the paper work presented because it is unclear. At the very least, improperly filled out applications will delay accreditation and may cause prices to increases to accommodate the increased scrutiny required when dealing with independents.

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Does CMS Have Enough Bidders? We'll Know Soon!

Suppliers in the initial 10 competitive bidding areas have less than a week left to register for their user IDs and passwords--and the registrations will determine whether CMS gets the number of bidders it had expected.

Providers who want to participate in the first round of Medicare bidding must register by Aug. 27 in order to access CMS' Internet-based bid submission system.

On July 27, the previous bidding deadline, CMS extended its bid window until Sept. 25. Bidders must be accredited or be in the process of becoming accredited to submit a bid. First-round bidders now have until Oct. 31 to become accredited in order to win a contract.

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Is It Any Wonder?

Is it any wonder pharmacists aren’t rushing to obtain accreditation or competitively bid to sell DME! On a positive note, diabetic testing supplies, at least in this first round, are exempt.

However, what is not so good is that CMS has yet to set a date when all suppliers must obtain accreditation.

Additionally, with its selection of less than $3.5 million in aggregate sales as the benchmark for defining a small DMEPOPS supplier, CMS has removed the incentive for small supplier pharmacies to competitively bid. Typically, only 8 percent of a pharmacy's sales come from DMEPOS products, and most of that is from diabetes testing supplies.

Now, add the proposed requirement that suppliers must spend an additional $2,000 to obtain a $65,000 surety bond to bill Medicare, and you can see why pharmacists aren’t banging down accreditation agency doors.

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OK, Now I Dare You to Cross This Bid Line

Early last Friday, CMS issued notice that it was extending the window for DMEPOS competitive bidding an additional 60 days. This extension was granted to allow suppliers additional time to consider their bid submissions in the 10 bidding areas, and to have the opportunity to update their bids based.

“We wanted to make sure DMEPOS suppliers in the bidding areas had all the available information to them to make informed, yet competitive bids,” said Acting CMS Deputy Administrator Herb Kuhn. Well, there you have it!

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The Centers for Medicare & Medicaid Services (CMS) is extending the bid submission, registration, and accreditation deadlines!

The Centers for Medicare & Medicaid Services (CMS) is extending the bid submission, registration, and accreditation deadlines for the first round of the Medicare Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) Competitive Bidding Program.


Please note: All bids are now due by 9:00 p.m. prevailing Eastern Time on September 25, 2007. Suppliers that have already submitted their bids may revise and resubmit their bids until the new deadline. Suppliers that resubmit bids must submit a new certification statement.

• On May 15, 2007, CMS issued a request for bids for the first round of the Medicare DMEPOS competitive bidding program. The original due date was 9:00 p.m. prevailing Eastern Time on July 13, 2007. All bids are now due by 9:00 p.m. prevailing Eastern Time on September 25, 2007.
  
• Suppliers interested in bidding must first register and receive a User ID and Password before they can access the internet-based bid submission system. Registration opened on April 9, 2007. The original registration deadline was June 30, 2007. CMS has reopened registration. The registration deadline is now August 27, 2007.
  
• Suppliers must be accredited or be pending accreditation to submit a bid and will need to be accredited to be awarded a contract. The accreditation deadline for the first round of competitive bidding was originally August 31, 2007. The accreditation deadline is now October 31, 2007.
  
• CMS is revising the contract periods. The original contract period for mail order diabetic supplies was April 1, 2008 – December 31, 2009. The contract period for all other first round product categories was April 1, 2008 – March 31, 2011. The contract period for mail order diabetic supplies is now July 1, 2008 – March 31, 2010. The contract period for all other first round product categories is now July 1, 2008 – June 30, 2011.
  
• CMS is providing a targeted period to address suppliers’ remaining questions on the competitive bidding program. To help ensure that answers are available as soon as possible, please e-mail your questions to the Competitive Bidding Implementation Contractor (CBIC) no later than August 10, 2007. The e-mail address is cbic.admin@palmettogba.com .
  
• There are revised customer service hours at the Competitive Bidding Implementation Contractor (CBIC). Effective immediately, the CBIC help desk will be available to assist you from 9 a.m. until 9 p.m. EST, Monday through Friday. You may call the help desk at 877-577-5331.

For more information on the program, please visit http://www.dmecompetitivebid.com/ .

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CMS Help Desk Hours Extended Along With Bidding Deadline

CMS announced last week that it is giving providers one more week to submit bids for national competitive bidding.

The new deadline: 9 p.m. EST on July 27.

It's the second time CMS has extended the deadline. CMS also pointed out that it has revised its customer service hours to 6 a.m. to midnight EST. The help desk (877-577-5331) will operate 24 hours the day before bidding closes.

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Are You Selling DMEPOS at a Loss?

Winning suppliers must be careful not to provide DMEPOS items at a loss to Medicare beneficiaries. Under the median price methodology, half of the “winning” bidders will be paid for DMEPOS at a rate below what they bid. The other half will have their bids RAISED to the median. So, if your bid was as low as you could go and you are a winning bidder above the median bid, your bid will be lower -- potentially below your costs. The final rule on competitive bidding doesn’t say whether those providers can withdraw from the program.

Accordingly, for this reason and others, a group of senators and representatives this week plans to send CMS two letters signed by more than a dozen of their colleagues urging the agency to delay national competitive bidding, but I would not hold my breathe. Sens. Pat Roberts, R-Kan., and Kent Conrad, D-N.D., and Reps. Tom Allen, D-Maine, and Sam Johnson, R-Texas, crafted the sign-on letters, which ask CMS to address several issues before closing the bidding window and implementing the program.

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CMS Controls Will Deter Diabetic Supply Billing Fraud

Last week, the Competitive Bidding Implementation Contractor (CBIC) website was updated with several Q&As regarding mail order diabetic supplies. In addition, most Q&As relating to the mail order competitive bidding program were reorganized under a separate "Mail Order" page under the "FAQ" section of the CBIC website.

The web address is: http://www.dmecompetitivebid.com/cbic/cbic.nsf/
123c46a12e4607f9852572330015b04f/7e55e2e7632b8e048525730f006d86c7?OpenDocument.

Medicare payment will NOT be made to non-contract suppliers that furnish mail order diabetic testing supplies to Medicare beneficiaries residing in a CBA. A special modifier will be used on each claim to indicate that the item was furnished on a mail order basis. Suppliers who furnish diabetic testing supplies on a mail order basis and do not attach the mail order modifier could be subject to significant penalties.

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DMEPOS Bid Deadline Extended; Accreditation Deadline Remains August 31 for Bidding Suppliers

The Centers for Medicare & Medicaid Services (CMS) is extending the registration and bid submission deadlines for the first round of the Medicare Durable Medical Equipment, Prosthetics, Orthotics and Supplies(DMEPOS) Competitive Bidding Program.


All bids are now due by 9 p.m. prevailing Eastern Time July 20, and the registration deadline is July 7.

The accreditation deadline for the first round of competitive bidding REMAINS August 31. Suppliers should apply for accreditation immediately to allow adequate time to process their applications. For a list of the CMS-approved Deemed Accreditation Organizations, visit: http://www.cms.hhs.gov/CompetitiveAcqforDMEPOS/.

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Accreditation Problems on the Rise for Bidding Suppliers

Suppliers who suspect their area may be included in the next round of competitive bidding should get accredited ASAP, say accreditation agencies.


As suppliers in the first 10 MSAs now scramble to get accredited, all kinds of problems have developed. For example, in their mad dash to submit the necessary paperwork, surveyors have noted, many suppliers "are not submitting the appropriate information" and cannot be surveyed until they do.


Additionally, accreditation agencies have seen an increase in the number of suppliers who submit the appropriate paperwork, but fail their surveys.


Remember, accreditation is more that just a manual stating your quality standard policies and procedures. It is principles that must be woven into the fabric of your business.

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OIG Implies Suppliers Have No One to Blame but Themselves

The Office of Inspector (OIG) conducted random supplier site visits in 2001. Of 169 DMEPOS suppliers sampled, 10 did not exist at their business address, yet they billed Medicare almost $393,000 in the two months AFTER CMS determined that they were absent. Fast forward to 2007 and CMS-1270-F - - mandatory accreditation. Make sense now?

DME Winning Contract Supplier Profitability NOT a CMS Concern

This question was asked at one of the CMS bidder’s teleconferences conducted last week

Question – What if the price of a product goes sky high and exceeds the contract reimbursement? Are you allowed to refuse the patient based on profitability?

Answer – No, a contract supplier MUST accept assignment.

At least five winning suppliers are anticipated per competitive bid area.

At least five winning suppliers are anticipated per competitive bid area.

The supplier capacity is calculated to ensure that the expected beneficiary
demand, in the CBA for the items in the product category, is met. Suppliers’
estimated capacity will be limited to 20% to ensure that at least five suppliers
are awarded a contract, if at least five eligible suppliers submit bids within the
product categories. Remember that 30% of the winning suppliers must be small providers.

That is 1.5 small suppliers right? Any one-half suppliers bidding in the first round?

LOL

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CMS is Puzzled

I tried to tell them. Most pharmacies now gross more than $3.5 million in total sales; thereby removing them from small supplier status. With diabetes testing supplies exempt from competitive bidding at retail, and no deadline for accreditation outside of the ten MSAs, is it any wonder that pharmacies are not beating down the doors of accreditation agencies!

Nonetheless, you should take advantage of this temporary reprieve and prepare for accreditation NOW. Sooner or later, its going to get to you!

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Competitive Bidding Webcast Now Available

An educational webcast is now available at the Competitive Bidding website, www.dmecompetitivebid.com. (Suppliers > education tools> webcast) The presentation is designed to help suppliers that intend to participate in the Medicare DMEPOS Competitive Bidding Program being implemented in 10 metropolitan areas throughout the United States.

The webcast highlights key bidding dates, provides an overview of the Competitive Bidding Program, and guides bidders through required application forms. Suppliers may view it at any time and submit questions at the conclusion of the presentation.

The Competitive Bidding website contains other helpful educational materials for suppliers, including a supplier tool kit, fact sheets, frequently asked questions, and more. For more information, call the Competitive Bidding Helpline at (877) 577-5331.

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Competitive Bidding Begins TODAY

From the Centers for Medicare & Medicaid Services:

CMS announced today that the Agency is now soliciting bids for the first round of the Medicare competitive bidding program for durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS). All bids are due by 9 p.m. E.S.T. on July 13, 2007.

For each competitive bidding area under the program, CMS has issued a detailed chart providing important bidding information for suppliers. Suppliers should use these charts when preparing their bids. The competitive bidding areas, product categories, bidding information charts, and full instructions for submitting a bid are located on the Competitive Bidding Implementation Contractor (CBIC) web site at www.dmecompetitivebid.com. Additionally, information about the types of suppliers each accrediting organization is approved to accredit and how to contact an accrediting organization is posted on the CMS website at www.cms.hhs.gov/CompetitiveAcqforDMEPOS/.

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NCPA/PRS Seminars Scheduled for First 10 MSAs; Accredit and Bid Smart!

I’ll be doing my best Willie Nelson impersonation May 22nd through June 14th when I’ll be “on the road again” visiting the first 10 MSAs selected for competitive bidding. NCPA and PRS will be conducting seminars in these MSAs that will provide business tools to assist pharmacists through the accreditation and DMEPOS bid process.

I will be speaking on understanding your DMEPOS claims processing business costs. And, explaining which services are essential or non-essential to providing service that meets or exceeds CMS quality standards.

For more information on these seminars – locations, dates, and times – or to register, click here.

I hope to see you all at one of these seminars.

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Understanding DMEPOS Service Costs

I’m getting mixed messages from accreditors regarding the volume of applications coming into the agencies. Like the first year of a new model car, it looks like the bidding suppliers in the first 10 MSAs (http://pharmacistelink.com/medicaredme/msas.asp) are going to work the “kinks” out for the rest of us. They have an August 31 deadline.

Additionally, many pharmacists not bidding are waiting to see if market pricing will settle further. Many independents, unlike their chain competitors, do not maintain policy, procedure, and protocol manuals. This has slowed down the accreditation process for some.

Starting on May 20th, PRS Pharmacy Services will be conducting seminars (Register online at https://secure.prsrx.com/dmepos/1DaySeminarReg.html) in the first 10 MSAs to assist pharmacists in creating manuals and understanding DMEPOS competitive bidding opportunities. Yours truly will be speaking there about “activity-based costing,” which is just a fancy way of analyzing DMEPOS service costs on a per unit basis. Understand your costs and you will know how aggressively you can bid.

On a bright note, NABP (http://www.nabp.net/) says there is no backlog and they are ready, willing, and able to quickly process and survey bidding suppliers to meet CMS accreditation deadlines.

Accurate Supplier Information a Must for DMEPOS Bidding

Maintaining accurate supplier information is important if you plan to competitively bid. If you have had a recent change and have not notified CMS, you are at risk of being excluded from the program.

CMS reiterated its current information requirement in an e-mail that stated “DMEPOS supplier standard # 2 requires all suppliers to notify the NSC (National Supplier Clearinghouse) of any change in information provided on CMS form 855S application form within 30 days of the change.”

Go to the NSC website, www.palmettogba.com/nsc, to submit any change of supplier information.

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August 31: Accreditation Deadline for First Round Competitive Bidding Suppliers

The accreditation deadline for suppliers participating in the first round of competitive bidding is August 31.

Participating suppliers must be accredited before this date in order to be awarded a contract. Suppliers wishing to participate in the competitive bidding project should apply for accreditation immediately in order to allow adequate time to process their applications. To complete this initial registration and obtain an User ID and password, please go to https://applications.cms.hhs.gov.

Bidding is expected to open in late April 2007. Only suppliers that are bidding must meet the August 31 deadline. CMS has NOT set a date for non-bidding suppliers to obtain accreditation.

Initial Supplier Registration for DMEPOS Competitive Bidding Open

I just participated in a CMS briefing for members of the Program Advisory and Oversight Committee for DMEPOS competitive bidding. I have verified that EVERY bidder must be accredited or have submitted an application to become accredited or their bid will be rejected. The first steps to submitting a bid start with suppliers registering to access online tools.

Start here: http://www.cms.hhs.gov/MLNMattersArticles/downloads/SE0717.pdf.

This includes ALL suppliers of durable medical equipment that wish to participate in the Medicare Competitive Bidding Program for durable medical equipment, prosthetics, orthotics, and supplies.

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An Easy Way to Find Your MSA

Here is a link to some easy to read maps that detail the DMEPOS competitive bid areas in the first 10 MSAs selected,
http://www.dmecompetitivebid.com/cbic/CBIC.nsf/(Pages)/Competitive+Bid+Areas.

You can search by zip code as well.

Areas outside of the MSAs are designated as rural locations, currently exempt from competitive bidding. However, you still MUST be accredited to maintain you Part B supplier billing number.

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Accreditation Required for All DMEPOS Suppliers…Except

Suppliers of durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) must obtain accreditation or at least have applied for accreditation from a CMS-approved agency IF they contemplate bidding on DMEPOS.

The ONLY exception to the rule is a pharmacy that maintains a Part B supplier billing number in order to submit Part B drug claims and administer vaccinations.

These supplier pharmacies must meet the current 21 national supplier clearinghouse (NSC) standards, BUT do not have to obtain any further accreditation.

Remember though, if you bill for just ONE box of glucose test strips at retail you must obtain accreditation.

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Competitive Bidding: Community Pharmacy, Beneficiaries with Diabetes Win

Congratulations NCPA members! Your e-mails, completed surveys, letters, and phone calls alerting Congress to the burdensome impact Medicare Part B billing supplier standards would have on your ability to provide access to important DMEPOS has been heard loud and clear.

NCPA’s successes include:

1. Modifying accreditation standards so they take into consideration the already stringent standards pharmacies and pharmacists must comply with on the state level.


2. Reducing accreditation agency fees and the introduction of pharmacist-friendly DMEPOS accreditation agencies (i.e. NABP, HQAA).


3. The exclusion of diabetic monitors and testing supplies from competitive bidding for retail suppliers ONLY. Mail-order firms must competitively bid.


4. Protections that require 30 percent winning bidders be small suppliers.

The bidding process will begin later this month, with CMS accepting bids for 60 days. Winning bids will be announced in December. CMS will use the median of the winning bids to establish “Medicare single payments,” which will apply universally to like products within each CBA. The Medicare single payments will replace current fee schedule amounts for those products, and will go into effect in April 2008.

If you plan to competitively bid, submit you accreditation application today! For more information on accreditation, visit NCPA’s DME Resource Center at www.pharmacistelink.com/medicaredme.

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DMEPOS Networks: Advantage Chains

CMS currently allows drug stores chains with common ownership to obtain DMEPOS accreditation with only 25 to 35 percent of its locations (accreditor determined) being surveyed; thereby, lowering costs. Obviously, ALL locations must meet CMS’s DMEPOS quality standards; however, this proves to be a big advantage for chain drugstores.

If the 2003 MMA states that small suppliers should have every opportunity to competitively bid, then doesn’t it stand to reason that CMS should provide similar cost savings opportunities to independents?

Pharmacy buying groups currently meet insurer quality standards and bid on behalf of member pharmacies. CMS should take a creative approach to the challenges and costs associated with its accreditation requirements. Lowering accreditation costs WILL result in more community pharmacies competitively bidding; thereby, improving beneficiary access to needed DMEPOS products and services.

Developing…

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Competitive Bidding Final Rule at OMB

CMS's final rule for national competitive bidding is in clearance at the Office of Management and Budget (OMB). This is not the first time the industry has expected, but not seen, the final rule. However, this time, it was actually published on the agency's docket.

What I really don’t understand is that if competitive bidding is to begin in October 2007, as has been signaled to the industry in the past, what challenges are holding up the release.

The Government Printing Office will publish the rule in the Federal Register and CMS will post it on its Web site as soon as it clears the OMB. This should occur quickly.

I expect the rule to outline CMS's timeline for rolling out competitive bidding. I’m hopeful CMS will finally identify the first 10 metropolitan statistical areas AND the DMEPOS product categories.

Keep your fingers crossed that CMS will have the good sense to exclude diabetic testing supplies.

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Observations from NCPA's Steering Committee Meeting

Community pharmacy leaders from throughout the country converged on NCPA headquarters in Alexandria March 8th and 9th to address the challenges and opportunities that lie ahead for our profession.

Regarding DMEPOS, almost every steering committee member I spoke with was still perplexed and a little unsure of the facts. Most were wondering what steps they should take to protect their businesses when accreditation deadlines are set by CMS and competitive bidding for DMEPOS begins.

My best advice for them and you is to sign up for the DMe-Alert newsletter. You will get updates on accreditation and competitive bidding as NCPA receives them from CMS. While NCPA cannot make your business decisions for you, be assured that NCPA will have you asking the right questions to make economically-sound decisions for your pharmacy.

I hope to see many of you at the NCPA Legislative Conference NCPA Legislative Conference scheduled for May 13-16 in Washington, DC.

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The PAOC Blues

It sounded like a good idea at the time. In 2003, one independent pharmacist, yours truly, was selected as one of 20 DMEPOS industry stakeholders to become a member of the CMS Program Advisory and Oversight Committee (PAOC).

Mandated in Section 302 of the MMA, the goals of the PAOC are to provide advice on the following:

1. The implementation of the Competitive Acquisition Program (CAP) (competitive bidding).
2. The establishment of financial standards that take into account the needs of small providers. The establishment of requirements for collection of data for the efficient management of the program.
3. The development of proposals for efficient interaction among manufacturers, providers of services, suppliers, and individuals.
4. The establishment of quality standards.

The problem is that while the committee can propose changes in the development and implementation of the program, CMS is under NO obligation to accept the recommendations.

To be fair, some of our recommendations have been adopted, such as not starting the program in the largest MSAs like New York, Chicago, or Los Angeles in the first round in 2007.

However, in other instances, PAOC recommendations have not been accepted. A case in point was the committee's unilaterally strong objections to the proposed DMEPOS rebate program, which would allow suppliers submitting a bid below the single payment amount to provide a rebate to the beneficiary. Fraught with disturbing accountability fears and disquieting fraud concerns, this program is still on the table.

Regretfully, the PAOC has “no teeth.”

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Options for Medicare Beneficiary with Diabetes?

Community pharmacists maintain one of every three Medicare Part B supplier billing numbers; thereby, providing easy access to necessary supplies for patients with diabetes. What if the number of DMEPOS pharmacy suppliers is reduced by 50 percent? That’s exactly what CMS expects with the implementation DMEPOS competitive bidding.

Even though there are more than 150,000 billing numbers out there, if you look at the supplier breakdown link on the DME Resource Center (http://www.pharmacistelink.com/medicaredme/nsc.asp), it is clear that without community pharmacists, access is severely restricted, unless you want to use mail order! (Hmm …never heard of that before).

One of the first questions I asked as a member of the PAOC was what affect did limiting access in the demonstration areas of Polk County and San Antonio have on shifting beneficiary DMEPOS expenses to the Medicare Part A benefit. I was particularly interested in diabetes testing supplies. CMS has their eye on that category as it represents 9.5 percent of all Medicare DMEPOS expenditures.

Incredibly, I was told this assessment was not part of the original plan design. Additionally, and much to my dismay, diabetes testing supplies were not even part of the original competitive bidding demonstration projects.

Respected 2006 studies shared with CMS indicate that if Hemoglobin A1c levels rise slightly in just 5 percent of beneficiaries with diabetes, then CMS should expect a 10 fold increase in Medicare Part A expenditures in the form of increased hospitalizations for diabetes related complications.

NCPA continues to petition CMS to exempt diabetes testing supplies from competitive bidding. At the very least, a demonstration project is warranted to assure that limiting diabetic testing supplies in community pharmacies will not trigger the cost shifting described. The jury is still out.

After all, I thought the number one reason for competitive bidding was to protect the beneficiary.

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DME Questions…

I traversed the snow covered Appalachian Mountains last Friday to visit PRS Pharmacy Services (www.prsrx.com) in Latrobe, Pa., 30 miles outside of Steel City. As a Baltimore boy, it was a little uncomfortable running into so many black and gold Pittsburgh Steeler fans, but I pressed on and found it was worth the trip.

I was in search of products and services that may assist pharmacists in understanding the economics of competitive bidding and how to streamline the accreditation application and survey processes.

If I put on my 22-year-old independent pharmacy owner hat, the first questions I would ask regarding accreditation and competitive bidding include:

1. Is it still profitable for me to be in the DME business?
   
2. Can I handle the additional, lower margin business? (CMS expects that winning bidders should be able to increase service capacities by an additional 20%)
   
3. If I exit the DME marketplace, what will be the economic impact on my prescription business?
   
4. Who can assist me in creating or updating my business policy, protocol, and procedure manuals that will serve as evidence to accreditation agencies that my facility complies with the new CMS quality standards?

Check PRS out. See if what they have fits your business needs. Remember, manuals are more than just the paper on which they are written. Surveyors will expect the pharmacist in charge (PIC), or other designee, to be able to discuss the standards and provide evidence that the policies are woven into the fabric of your business.

Stay tuned…

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Don’t Lose Sight of the Big Picture

CMS estimates that 90% of suppliers in the top 10 metropolitan statistical areas (MSA) will competitively bid on DMEPOS in an effort to hold on to or grow their Medicare business. They also estimate that 50% would likely become “winning bidders,” representing approximately 18,000 suppliers located in the top 10 MSAs.

(Keep your eyes open Miami!)

According to NCPA surveys, less than 10% of independent community pharmacies are accredited – allegedly the first step to competitively bidding. Accreditation agencies have a big, and possibly insurmountable, challenge in meeting CMS accreditation deadlines.

I wish I knew what those deadlines were so I could share them with you, but CMS has not been clear in sharing that information. One thing is sure, while CMS would “like” suppliers to obtain facility accreditation PRIOR to submitting a bid to provide DMEPOS to beneficiaries, CMS has the authority to proceed with competitive bidding whether suppliers are accredited or not.

Stay tuned!

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Welcome to the DME blog

Hello Friends!


I’m William “Bill” Popomaronis, R.Ph., vice president, long term and home health care services for the National Community Pharmacists Association (NCPA). Welcome to my DME Blog. This is where we will discuss the latest information on CMS’s DME Accreditation and Competitive Bidding programs. My goal is to answer your questions, provide the facts, and clear up the rumors and innuendo related to these topics.

I have special insight because I am the only pharmacist member of Medicare’s Program Advisory and Oversight Committee (PAOC), which provides advice on the development and implementation of the DME Competitive Acquisition Program, and in my role at NCPA, it is my job to study these regulations so you don’t have to.

This blog is part of a bigger DME Resource Center located on Pharmacist e-Link ™ (www.pharmacistelink.com/medicaredme). The Resource Center is provided by NCPA with support from Bayer HealthCare, Diabetes Care. It includes fast facts and resources concerning accreditation, competitive bidding, NSC supplier standards, as well as the DMe-Alert service providing you the latest, fact-based information via an email newsletter once each week.