WASHINGTON, D.C. – AAHomecare, allied industry groups, state & regional HME associations, patient and clinician organizations, and HME suppliers, manufacturers, and distributors across the country are weighing in on the Proposed Rule and the return of an even-more-flawed version of the bidding program.

If you and your company aren’t planning on submitting comments, please take a moment and reconsider. We’ve heard of two reasons that are holding some people back – and we’d like to share some perspective on both, as well as a fresh resource for sharing comments.

Reason 1: I don’t know what to say / I don’t know how to make comments.
We understand that the scope of the Proposed Rule and the technicalities with some of the issues can feel daunting. But sharing comments doesn’t have to be complicated or exhaustive. You can find guidance on our Proposed Rule Commenting Resources page – as well as this plain language summary and commenting advice on major issues with the proposed rule.

You don’t have to comment on every issue; comments that cover just a few issues – or even one issue – are helpful and impactful.  Look at the summary, pick out the ones that resonate with you the most – and tell CMS how they will impact your business and your patients.

The issues you know best – and can talk about how they’ll impact you – are what to focus on.  Effective comments would include sharing your experience running your business and serving your patients, while explaining what the proposed rule, if enacted, would mean for you.

Reason 2: I’m not in a Competitive Bidding Area / I don’t do much FFS Medicare business, so this doesn’t impact me.
These rates will impact all Medicare rates for products included in the program – even in rural areas that receive the 50/50 blended rate. And the rates from the bidding round will also guide Medicaid rates in 32 states(see graphic below), set rates for TRICARE, and influence Medicare Advantage plans and private insurance payers that use the Medicare rates to help inform their rate-setting. Proposed annual reaccreditation requirements will be a burden for all Medicare providers, as well.

Don’t Miss Your Chance to be Heard
The return of the Competitive Bidding Program as currently envisioned in the Proposed Rule could have a catastrophic impact on the HME sector. With stakes this high, you can’t stay on the sidelines! Share your perspectives on the Proposed Rule with CMS by Friday, Aug. 29.  

Additional Resources for Commenting

• Comprehensive AAHomecare Comment Resources– includes link to our Aug. 6 webinar on the Proposed Rule and other materials to help you understand the Proposed Rule and share comments.
• Updated Commenting Guidance for AAHomecare members and the HME community–
• Plain Language Summary and Commenting Advice– as featured in Reason 1 section above.
• Submit your comments to CMS here
• Tips for submitting effective comments from Regulations.gov.