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CBIC Backtracks & Removes Ventilators from Round 1 2017

Tuesday, June 9th, 2015

Angela Hayden

 

In a listserve posted on June 4th, 2015, the CBIC announced the removal of Non-Invasive Pressure Support Ventilators from Round 1 2017.  The E0464 was introduced as a stand-alone product category for this particular round of bidding in April 2015. Bidding for this round has not yet begun, which allows the CBIC to process these kinds of changes.

 

CMS has recently released a number of educational bulletins and Joint DME MAC publications to inform suppliers that Ventilators are not appropriate for the treatment of OSA and those conditions covered in the Respiratory Assist Device (RAD) policy (Complex Sleep Apnea, Central Sleep Apnea, Hypoventilation Syndrome, etc).  Because of advancements in technology, some ventilators are able to operate in PAP or RAD modes, therefore suppliers are incorrectly utilizing these ventilators in place of a PAP or RAD device.

 

With the announcement, CMS also announced plans to consolidate current ventilator codes into two codes effective December 31, 2015.  As of December 31st, the following codes will be obsolete:

 

  • E0450 – Volume control ventilator, without pressure support mode, may include pressure control mode, used with invasive interface (e.g., tracheostomy tube)
  • E0460 – Negative pressure ventilator, portable or stationary
  • E0461 – Volume control ventilator, without pressure support mode, may include pressure control mode, used with non-invasive interface (e.g.,mask)
  • E0463 – Pressure support ventilator with volume control mode, may include pressure control mode, used with invasive interface (e.g., tracheostomy tube).
  • E0464 – Pressure support ventilator with volume control mode, may include pressure control mode, used with non-invasive interface (e.g., mask)

 

CMS will replace the above codes with two new codes that have yet to be assigned, but will be effective January 1, 2016:

 

  • Exxx1 – Home ventilator, any type, used with invasive interface (e.g., tracheostomy tube)
  • Exxx2 – Home ventilator, any type, used with non-invasive interface (e.g., mask, chest shell)

 

Exxx1 will be used in place of HCPCS E0450 and E0463, while Exxx2 will be used for HCPCS E0460, E0461, and E0464.  In terms of fee schedule, CMS will establish the fee schedule amounts for the new codes using the current fee schedule for E0450, which varies in allowable (depending on state) from $868.40 to $1,761.50.  CMS also noted in this bulletin that they “intend to closely monitor” the use of the newly established codes to ensure that items used for the treatment of OSA are not being billed under these codes.

 

CMS is accepting comments for consideration on these changes through 5pm on June 25, 2015 at codingcomments@cms.hhs.gov.  Suppliers that wish to submit a comment should make the subject line “Ventilator Comments”. See the official notice here.

 

CBIC Announces Next Bid for Round 1 Areas in 2017

Wednesday, April 22nd, 2015

Angela Hayden

 

The Competitive Bidding Independent Contractor (CBIC) announced the next bidding competition for Round 1 areas in 2017.   This next round is to begin once the current Round 1 Recompete contracts expire on December 31, 2016.  Round 1 2017 will take place in the same nine Metropolitan Service Areas (MSAs) as the Round 1 Recompete; however, due to changes in the program and zip code updates the nine MSAs now break down into 13 Competitive Bidding Areas.  Those CBAs are:

 

  • Charlotte-Concord-Gastonia, NC
  • Chester, Lancaster & York Counties, SC
  • Cincinnati, OH
  • Cleveland-Elyria, OH
  • Covington-Florence-Newport, KY
  • Dallas-Fort Worth-Arlington, TX
  • Dearborn-Franklin-Ohio & Union Counties, IN
  • Kansas City, MO
  • Kansas City-Overland Park-Ottawa, KS
  • Miami-Fort Lauderdale-West Palm Beach, FL
  • Orlando-Kissimmee-Sanford, FL
  • Pittsburg, PA
  • Riverside-Bernardino-Ontario, CA

 

Product categories have also been shuffled in this next competition.  The major changes include:

 

  • The addition of Non-Invasive Ventilator HCPCS E0464 as a stand-alone product category.
  • TENS units were removed from the General Home Equipment category and established as their own separate bidding category.
  • Nebulizers and related supplies and accessories were also broken out from the Respiratory category to stand alone as their own bidding category.

 

The break out of these products as stand-alone product categories, provides flexibility for suppliers that supply only those products and not the remaining items in the General and Respiratory categories. To view the full list of HCPCS to be bid under this competition click here.

 

CMS has also established specific rules regarding the Ventilator category as this product will only be bid in a total of eight CBAs:

 

  1. Charlotte-Concord-Gastonia, NC
  2. Chester, Lancaster & York counties, SC
  3. Dallas-Fort Worth-Arlington, TX
  4. Kansas City-Overland Park-Ottawa, KS
  5. Kansas City, MO
  6. Miami-Fort Lauderdale-West Palm Beach, FL
  7. Orlando-Kissimmee-Sanford, FL
  8. Riverside-San Bernardino-Ontario, CA

 

Therefore bidding will not take place for the E0464 in: Cincinnati, OH; Cleveland-Elyria, OH; Covington-Florence-Newport, KY; Dearborn-Franklin-Ohio & Union Counties, IN and Pittsburg, PA.

 

This next round was announced April 21, 2015, and bidding is projected to begin this fall.

 

Electronic Bid Window Extended for Round 2 & National Mail Order Recompete

Thursday, March 26th, 2015

Andrea Stark

 

Due to some technical difficulties experienced in the electronic bid system, the CBIC extended the window to submit electronic bids to March 26, 2015 at 8:59 PM Eastern (this evening).

 

Keep in mind they did not extend the window for delivery of hardcopy documentation which still had be received by the CBIC no later than midnight on March 25th.  If your packet was not received by that deadline, it will not be accepted and your bid will be disqualified, even if it is postmarked before the deadline.

 

For bidders that submitted documentation in time for the Covered Documentation Review process, a notification will be sent by May 21, 2015 either confirming that your packet is complete or to notify you which financial documents were missing from your packet. Bidders will not receive email correspondence regarding receipt of the packet unless it was submitted by the Covered Documentation Review deadline of February 23, 2015.

The Clock Is Ticking: Recompete Registration Ends Soon

Friday, February 13th, 2015

Andrea Stark

 

If you are a provider participating in the Round 2 or National Mail Order Recompete programs for Competitive Bidding contracts, and you have not yet registered, time is running out.  The Competitive Bidding Implementation Contractor (CBIC) will close the registration window on Tuesday, February 17, 2015. Suppliers that have not yet registered (and wish to participate in bidding) will need to have the Authorized Official for the business establish an account via the CMS IACS system by 9pm EST on February 17, 2015.  Registration in the IACS system is required to obtain a user ID and password for the electronic bidding system DBidS. If you miss the registration deadline, you will not be able to submit a bid. Registering for an account provides you with the most flexibility, but does not obligate you to formally submit a bid.  If you are undecided, it is best to secure your access immediately.

As a recap, the following product categories are up for bid in Round 2:

 

  • Enteral Nutrition, 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

 

The National Mail Order contracts to supply mail order diabetic supplies are being recompeted on the same timeline. The covered documentation review deadline is February 23, 2015. Suppliers that wish to have their required documentation packets reviewed for missing documentation must have that in by February 23rd. The bid window, however, will remain open until March 25, 2015. See the latest edition of VistaNotes (Volume 6 Issue 6, available for purchase on our products page) for a condensed, but comprehensive, bidding guide for suppliers.

 

Licensing Challenges, Lawsuits and Prospects for Delay as Bidding Implementation Approaches

Thursday, June 20th, 2013

Andrea Stark

 

MiraVista continues to monitor the situation with contracted providers under Round 2 of competitive bidding.  We have been able to confirm, based on a letter from Marilyn Tavenner to Congressman David Roe from Tennessee, that approximately 30 Tennessee contracts were voided out of 98 awards.  CMS indicates they do not intend on immediately awarding replacement contracts (relying on in-state suppliers and grandfathered suppliers), but will “closely monitor the situation in the state”.

 

With voided contracts in Tennessee, these providers will not jeopardize the entirety of their CBIC contracts by not having everything in place on the start date of July 1, 2013. While disruptive, MiraVista maintains this is a welcome reprieve.  Most of these providers relied on the licensure database housed on the National Supplier Clearinghouse website when submitting their bids back in January 2012.  The database did not accurately reflect all of the states licensure requirements (specifically for Tennessee).   Most of the providers who received voided contracts were unaware of the additional licensing requirements that also mandate a brick-and-mortar location approved by the state to dispense any medical equipment in that state. These providers were notified by the CBIC on or about April 15, 2013 that contracts had been awarded based on the same, incomplete licensure information contained in the database (and not according to actual state licensure requirements in place at the time of bid submission, as was required by law).  The April letter directed the suppliers to submit a complete 855-S form to enroll a new TN location for their organization.  Submission of the application requires prior licensure approval, accreditation, and surety bonds for the new location. The Medicare application process to enroll a new location takes at a minimum 45-60 days.  All combined, it was an insurmountable feat to get all of this finalized with approximately 75 days’ notice start-to-finish.  Having these “problematic” contracts voided, takes the pressure off the risk of non-compliance and subsequent breach and loss of all other contracts in unaffected states.

 

We know other states have cited that the CBIC has awarded contracts to providers that do not meet licensure requirements in their state.  What remains to be seen is how CMS will address these other concerns.  MiraVista maintains that this is an increasingly complex issue CMS must contend with.

 

We believe other contracts will eventually be voided if the licensure requirements were in effect at the time of bid submission where licensure had not been procured by the supplier by the original, May 1, 2012 extension date. This precedent is now established with the Tennessee nullifications.  Yet we do not know how CMS will handle changing licensure requirements where rules change mid-stream.  Will they offer grace periods to allow contracted providers to come into compliance? We have learned that Mississippi now has a regulation similar to Tennessee in that a physical location is required to procure licensure, but the requirement was changed AFTER bid submission closed.

 

AAHomecare announced yesterday, June 19th that it has filed a lawsuit against the Health and Human Services in conjunction with a Maryland provider.  The lawsuit seeks to stop the program citing the licensing irregularities in other states to include: Colorado, Ohio, Maryland, North Carolina, Tennessee, Virginia and Washington.  We will continue to monitor the progress of this initiative.

 

We are most hopeful for the prospects of new legislation introduced just last week on June 14th, HR 2375 The Transparency & Accountability In Medicare Bidding Act of 2013.  The bill will mandate a minimum delay of six months for all bidding programs to include Round 2, National Mail Order and Round 1 Recompete.  Round 1 could not proceed until six months after Round 2 resumes.  It would obligate CMS to meet with three auction experts, an economist and an econometrician (collectively an “auction expert team”) for the purpose of an independent review and assessment of the program. The goal will be to address the design, development, adequacy of support for beneficiaries, market fairness, sustainability and functioning of the program.  It disqualifies any current or former CMS employee, contractor or individuals that were involved in the original creation or design of the program from being selected for the auction expert team. CMS will have to cooperate fully and disclose all confidential information related to the program to the auction expert team.  A report to include recommendations for changes must then be submitted to Congress within four months of engaging the auction expert team.

 

The bill gives us a real opportunity to elicit fundamental change which is desperately needed.  A Dear Colleague letter contained the foundation for the bill’s text.  The letter was signed by 226 Representatives and delivered to CMS on June 13th.  The letter relies on CMS to make the call to delay, but to date, CMS shows no sign that they will consider a delay.  However, if we convert the co-signers on the letter to co-sponsors of the bill, we have a strong chance of getting passage in the house and can begin work in the Senate.  Passage of the bill will mandate CMS to suspend the program.  This could move quickly, but will not be complete in the two weeks before the program start date of July 1, 2013.

 

We cannot accept minor band-aid fixes that do nothing to address the unintended consequences of conducting a flawed auction program.  The current program has forced unnatural market trends.    This has produced so many shifts in geographical presence, product offerings, state licensing complexities, and unsustainable rates all in the interest of “survival” and not “true competition”.  Auctions like the Market Pricing Program can work for DME as set forth in HR1717, but competitive bidding in its current form will fall far short.

 

 

CBIC Retroactively Disqualifies Bids in the 11th Hour

Friday, June 14th, 2013

Andrea Stark

 

Contracted providers for MSAs in Tennessee report FedEx letters arrived this morning (June 14) from the CBIC declaring that select bids have been disqualified and previously awarded contracts would be amended to strike affected bid areas.  Specifically, bidders that did not meet state licensure requirements before May 1, 2012 are affected.  Curiously enough, CBIC contacted affected bidders by letter several weeks ago and granted a grace period, giving providers until July 1, 2013 to comply.

 

So where does this leave us?  There are a few possible outcomes…

 

With disqualified bids, CMS must revisit the single payment amounts and contracted rates.

 

The announcement of disqualified bids potentially invalidates the whole contracting process.  When a provider is disqualified, their bid amounts cannot be used in the calculation of the single payment amount.  This begs the question whether any of the previously awarded contracts are valid as they do not have accurate pricing.  Secondarily, if any contracted provider is disqualified, the CBIC will also have to add replacement suppliers.  It stands to reason that, in order to meet capacity requirements, the CBIC may have to advance up the bidder chain significantly to find qualified providers where licensure is currently in place.

 

CMS could announce a full or partial delay of the program. 

 

CMS may delay.  It takes time to execute new contracts and to recalculate single payment amounts.  Alternatively, CMS could decide to stick with the original schedule but not pursue contracting in the MSAs where licensure is an issue.  Precedent along these lines was established in Round 1 after capacity could not be acquired in the bid process for San Juan, PR.  This is an unlikely option, however, as we are not aware of any public notification or communications with unaffected contract providers.

 

MiraVista will continue to monitor the situation and will communicate developments as they become available.

 

Need Help Submitting Your Bid?

Wednesday, February 1st, 2012

The Competitive Bidding Implementation Contractor (CBIC) recently published a series of webcasts to assist suppliers in submitting their bids for Round 2 of Competitive Bidding and the national mail-order diabetic supplies program. The bid window opened on January 30, 2012 (click here for info on other critical dates).

 

Webcast topics include:

  • An overview of the Round 2 and national mail order competitions (published 12/20/11)
  • A webcast specific to the national mail order program for diabetic supplies (published 01/09/12)
  • Important program rules outlined in the Request for Bids (RFB) Instructions (published 01/13/12)
  • How a bid is evaluated (published 01/20/12)
  • Details on financial documentation requirements (published 01/25/12)
  • How to submit a bid (published 01/27/12)

The webcasts are free and available for viewing 24 hours a day, 7 days a week. In addition, a DBidS reference guide is also available to assist suppliers in using the online system to place their bids.


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