Regulatory update: AAH submits comments on bidding, makes recommendations for SMRCs

Thursday, April 13, 2017


WASHINGTON – AAHomecare reiterated it concerns about the structure of the competitive bidding process, including CMS’s use of median bid prices instead of market clearing prices, in recent comments submitted to the agency.

CMS was mandated by the 21st Century Cures Act to take into account stakeholder input on future pricing in non-bid areas, which got their first taste of the program in 2016.

In its comments, AAHomecare also asked for more comprehensive evaluation of the bidding program’s effects on beneficiary access and the quality of equipment furnished.

The comments also noted significant reductions in the number of HME suppliers in recent years and echoed the feedback shared by many suppliers on a March 23 call with providers.

“The stories told by suppliers and referral sources all had the same theme: the cuts are too severe, suppliers cannot exist on the current regional SPAs, Medicare beneficiaries are not being serviced at the level they need,” AAHomecare stated. “There was a sense of urging CMS to reconsider what has been done as part of the requirement in the Cures Act.”

AAHomecare closed its comments by asking what process CMS will follow to respond to industry feedback from the call and the written comments provided by stakeholders, and reiterated the association’s commitment to working with the agency to arrive at a workable payment solution.

AAH makes recommendations on SMRC contract

CMS requested that AAHomecare’s Regulatory Council provide suggestions on what should be included in the next statement of work for the SMRC contractor. Strategic Health Solutions’ contract is set to expire this year. Some of AAHomecare’s suggestions are:

• Change the time frame for response by a supplier from 30 days to 45 business days. 

• Limit the number of claims per letter to 20.

• Require the SMRC contractor to publicly publish error rates and overturn rates through all levels of appeal.

• Require the SMRC contractor to only look at new setups and not the random dates of service as they do now.

AAHomecare says it has previously worked with CMS on SMRC audit issues and appreciates the opportunity to continue to be involved in the process.