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Letter to Marilyn Tavenner, Administrator Centers for Medicare and Medicaid Services - Halt Expansion of Program Prior to HHS IG Review

Marilyn Tavenner
Centers for Medicare and Medicaid Services
Hubert H. Humphrey Building
200 Independence Avenue, SW
Washington, DC 20201

Dear Administrator Tavenner:

On behalf of Medicare beneficiaries and the durable medical equipment providers who provide services and supplies in our states, we write regarding the advanced notice of proposed rulemaking recently issued by the Centers for Medicare and Medicaid Services (CMS) titled, "Medicare Program; Methodology for Adjusting Payment Amounts for Certain Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) using Information from Competitive Bidding Programs" (RIN 0938--AS05). In this advanced notice, CMS asked for input on the Competitive Bidding program in advance of expanding the program nationally which must occur by January 1, 2016.

We appreciate that CMS is requesting input before moving forward, especially given the impact competitive bidding prices could have on rural areas. In these remote areas, DMEPOS are especially vital and necessary to resident beneficiaries, and we question whether an apples-to-apples comparison with urban areas is the best approach, especially since there are some concerns with the bidding process in Round 1 and Round 2.

The Health and Human Services Office of Inspector General (OIG) is currently examining the Round 2 bidding process. Before you move forward in implementing competitive bidding nationally, we request that you allow the OIG to complete their investigation on competitive bidding licensure problems and verification of Round 2 single payment amounts and give Congress time to review the results. It is important that we have the guidance of this review before moving forward with a national program.

We look forward to your response.


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