CLIENT ALERT
ROUND ONE OF THE MEDICARE COMPETITIVE BIDDING PROCESS IS UNDERWAY – ARE YOU PREPARED?
If you are a supplier of Durable Medical Equipment, Prosthetic, Orthotics & Supplies (DMEPOS) which you bill Medicare for, significant rule changes are about to change the way you do business. On January 16, 2009, the Centers for Medicare & Medicaid Services (CMS), the federal agency within the United States Department of Health and Human Services (DHHS) that administers the Medicare program and works in partnership with state governments to administer Medicaid, the State Children's Health Insurance Program (SCHIP), and health insurance portability standards, issued an interim final rule on the competitive bidding program necessary to conduct the Round 1 rebid competition in 2009. That rule became effective on April 18, 2009. To ensure that suppliers have ample time to prepare for the competition, CMS announced on May 29, 2009 the following progression for the program:
SPRING 2009
CMS BEGINS PRE-BIDDING SUPPLIER AWARENESS CAMPAIGN
PROGRAM ADVISORY AND OVERSIGHT COMMITTEE (PAOC) MEETING (JUNE 4, 2009)
SUMMER 2009
CMS ANNOUNCES BIDDING SCHEDULE/SCHEDULE OF EDUCATION EVENTS
CMS BEGINS BIDDER EDUCATION CAMPAIGN
BIDDER REGISTRATION PERIOD TO OBTAIN USER IDS AND PASSWORDS BEGINS
FALL 2009
BIDDING BEGINS
Don’t wait! If you are a supplier interested in bidding, you must take the following action now:
UPDATE YOUR NSC FILES: ALL suppliers must notify the National Supplier Clearinghouse (NSC) of any change to the information provided on the Medicare enrollment application (CMS-855S) within 30 days of the change. This is especially important for suppliers who will be involved in the Medicare DMEPOS Competitive Bidding Program. These suppliers must ensure the information listed on their supplier files is accurate to enable participation in the program.
GET LICENSED: Suppliers submitting a bid for a product category in a competitive bidding area (CBA) must meet all DMEPOS state licensure requirements and other applicable state licensure requirements, if any, for that product category for every state in that CBA. Prior to submitting a bid for a CBA and product category, the supplier must have a copy of the applicable state licenses on file with the NSC.
GET ACCREDITED: Time is running out. With limited exceptions, if suppliers are not accredited by the September 30, 2009 deadline, Medicare Part B billing privileges may be revoked on October 1, 2009. Without accreditation, a DMEPOS supplier may not be awarded a competitive bid. Further information on the DMEPOS accreditation requirements: may be found at the CMS website:
http://www.cms.hhs.gov/DMEPOSCompetitiveBid/01_overview.asp#TopOfPage
GET BONDED: Certain suppliers must obtain and submit a surety bond by the October 2, 2009 deadline or risk having their Medicare Part B billing privileges revoked.
This letter and Client Alert is a summary only, prepared for general informational purposes, and is not an exhaustive description of the DMEPOS Competitive Bidding Program and related issues. Nothing in this letter is intended to constitute a legal opinion or legal advice of the undersigned or Meyers, Roman, Friedberg & Lewis. If you would like to be removed from our e-mail distribution list, or no longer wish to receive our Client Alerts, please e-mail us at scox@meyersroman.com.
If you would like to discuss how these changes affect you or your business, or for a full description of the DMEPOS Competitive Bidding Program, please contact:
Mary Louisa L’Hommedieu, Esq.
Meyers, Roman, Friedberg & Lewis
28601 Chagrin Blvd., Ste. 500
Cleveland, Ohio 44122
(216) 831-0042
mlhommedieu@meyersroman.com
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