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In its continued efforts to fight the fatally flawed competitive bidding program, The Center for Regulatory Effectiveness (CRE) is asking the public to submit letters to CMS supporting the comments that beneficiaries have made on the CRE Web site.
During the fall of 2009, CRE asked VGM for assistance in obtaining feedback from Medicare patients who could be affected by the DME competitive bidding program (see CRE Launches DME Hotline). In response, VGM issued brochures to providers across the country that informed their patients about the program. The brochure also directed patients to contact CRE and express their concern and/or “unhappiness” with the “new law.” CRE then collected the information and made it part of the work product in addressing the regulatory effectiveness of the program. Comments from Medicare patients may be found here.
According to CRE, CMS has a “statutory requirement to assess the effectiveness of its competitive bidding program for durable medical equipment and report its findings to Congress.” Moreover, under the Paperwork Reduction Act, CMS must provide OMB with responses to the comments received. Therefore, it is crucial for the public to continue submitting comments and letters to CMS as well as to CRE so that the watchdog group may track them.
Detailed comments may include (but certainly are not limited to) items such as:
The need for CMS to ensure that the voices of Medicare beneficiaries are heard. Since many beneficiaries don’t have computers and are unaware of CMS procedures, the agency should use the Competitive Bidding IPD and Discussion Forum as one of their primary sources of information for beneficiary views.
The CMS Report to Congress and any other information disseminations based on the data collected under this ICR should be subjected to the pre-dissemination review provisions of the Data Quality Act and be provided to the public in draft for comment prior to the report being sent to Congress.
Any report on “on changes in the Medicare Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) market” needs to explicitly analyze the SBA-defined small DME suppliers including changes in the number of suppliers in the competitive bidding areas, changes in their share of the market and changes in their financial viability. CMS should consult with SBA on how to prepare the small business impact analysis.
NOTE: Original comments, as opposed to pre-drafted form letters are highly recommended. Government entities frequently recognize and widely disregard comments sent in form-letter fashion.
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