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NHIA Writes to CMS on Changes to "Supplier Standards"
March 25, 2008
Concerns include provision on subcontracting
Reflecting comments received from our members, NHIA has written the Centers for Medicare & Medicaid Services (CMS) about changes proposed to the "supplier standards” for Medicare Part B Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) products and services. Suppliers of DMEPOS products and services must meet supplier standards as a condition of participation in the program. CMS put forward changes to these standards in a proposed regulation published for a 60-day comment period ending March 25.
NHIA agrees with CMS’ general goals and objectives for the proposed changes. All legitimate stakeholders must work together to ensure that suppliers that participate in the Medicare program are genuine operations dedicated to the provision of quality care to Medicare beneficiaries. Likewise, suppliers must be responsive to beneficiaries’ changing needs and be able to communicate with beneficiaries appropriately about their care.
However, NHIA has provided suggestions where we believe the changes are too rigid or prescriptive. We are particularly concerned with the prohibition on suppliers’ abilities to subcontract with third parties to provide licensed services, such as subcontracting with pharmacists when necessary for a variety of reasons—for example: staff illnesses, vacations, staff turnover or unusually high demand. We have informed CMS that such subcontracting is extremely important to ensure that there are no interruptions in patient access to care.
Other concerns we communicated to CMS included the areas of "appropriate site” requirements, prohibition on sharing practice location, and requirements pertaining to suppliers’ communications with Medicare beneficiaries.
NHIA received a number of comments from its general membership including the NHIA Payer Relations Committee which were used in preparing the association’s comments on behalf of our infusion provider community.
- Read NHIA’s comments.
- View the proposed rule with changes to supplier standards.
- Read summary of proposed changes prepared by NHIA legal counsel.