AAHomecare Crafting Reply to ESRD/DMEPOS Proposed Rule

Association calling on providers to submit comments; says documenting negative impacts will help shape final rule.

After releasing some initial analysis and takeaway regarding CMS’s proposed ESRD and DMEPOS rule, the American Association for Homecare’s regulatory council is preparing its official comments, and is calling on providers to send their comments, as well.


Working with other stakeholder groups and outside counsel, the association is aiming to craft factual comments that make a sound argument for changes to the proposed rule that would benefit HME providers, patients, other medical professionals, and caregivers.


Public comments to the proposed rule are due Sept. 10.


Last week, AAHomecare President and CEO Tom Ryan noted that the proposed rule “falls short” in several areas. A statement from the association this week underscored that position.


“We are particularly concerned with the absence of relief for suppliers in non-bid areas that aren’t in specifically designated rural areas, as well as changes to oxygen reimbursement policy aimed at addressing budget neutrality requirements put in place more than a decade ago,” the statement read. “We believe a strong response from HME stakeholder groups and providers who are being negatively impacted by Medicare reimbursement policy is especially important as CMS deliberates on the final shape of the rule.”


To that end, AAHomecare stated that it hoped providers would add their voices to that effort and offered some guidelines on submitting public comments.


“The most important point to make in your comments is demonstrating how CMS’ policies on competitive bidding, rural/non-bid area rate-setting, and oxygen reimbursement policy are affecting your company and your ability to impact patients,” the association advised. “While you can comment at any time, you may wish to wait until we develop and share details on our main ‘asks’ and additional messaging over the next two weeks.”


Additional resources:

  • The Regulations.com site provides tips on submitting effective comments at bit.ly/2mLoE9i.
  • AAHomecare offers a summary of the proposed rule at bit.ly/2LSmXSm.
  • The text of the proposed rule at bit.ly/2mLoPS0.


About the Author

David Kopf is the Publisher and Executive Editor of HME Business and DME Pharmacy magazines. Follow him on Twitter at @postacutenews.

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