There are many aspects of competitive bidding, and there are both positives and negatives to the decisions CMS decided to take in Round 2021.
In VGM’s conversations with, and in comment letters submitted to CMS leading up to their recent decision, our requests always included the following components:
- Delay competitive bidding (this made sense from a demand and any-willing-provider standpoint)
- Continue the blended rates for rural and non-rural non-CBA areas, but also extend the 75/25 blended rates into the CBAs as well; the blended rates for both CBAs and non-rural, non-CBAs would need to continue until the next time those products could be re-bid under a fair bid program.
We were adamant that simply honoring request #1 above without also honoring #2 would not be sufficient and would result in access to care issues for several products in several areas. Unfortunately, they did not listen and did not implement both of our requests. Instead, they simply removed the 13 categories and left the pricing for the competitively bid products as is for the CBAs. VGM is not 100% satisfied with the outcome of Round 2021. While there were some insufficiencies that were addressed longer term, like the continuation of the 50/50 blended rates for rural areas, there were others that were completely neglected.
With the high rate of DME business closures that continues to exist, it remains clear that the rates that came out of the previous rounds of competitive bidding remain unsustainable for too many businesses. While rural areas will continue to receive relief in the form of higher payments, the non-rural, non-CBAs will only receive relief through 4/1/2021 or the end of the PHE, and CBAs will receive no relief at all, except for a CPI-U increase. These areas still need to be addressed. VGM remains committed to finding a solution that offers relief to our members in ALL areas of the country.
Together we will stay the course. We will continue to...
- Pull the Good, Bad & Ugly from the 200+ page proposed rule and keep you updated.
- Focus on Budget Neutrality (HR8158) during the lame duck session.
- Prepare a template for our membership to utilize during the comment period once announced.
- Work with industry stakeholders on CBA & Non-Rural relief to address unsustainable rates once the PHE concludes or April 1 (whichever is later).