Special Report: Alliance Organizations Address Impact of Support Surface Competitive Bidding with CMS

Marcia Nusgart, RPh

    Alliance of Wound Care Stakeholders representatives had the opportunity to educate Centers for Medicare and Medicaid Services (CMS) officials on the effect of support surface competitive bidding on physicians, clinicians, manufacturers, providers, and (most importantly) Medicare patients at the Program Advisory and Oversight Committee (PAOC) meeting, September 26–27, 2005, Baltimore, Md.

The PAOC was assembled to advise the CMS on crafting a competitive bidding program for durable medical equipment prosthetic and orthotic supplies (DMEPOS), to be implemented in 2007. Currently, the products to be competitively bid have not been selected; however, stakeholders are awaiting publication of a proposed rule that will detail criteria for site selection, item selection, the bid evaluation process, and structure for implementation.

    Alliance organizations, including The National Pressure Ulcer Advisory Panel, Wound Ostomy Continence Nurses Society, Coalition of Wound Care Manufacturers, and National Association for Support of Long Term Care, nominated three speakers to serve on the PAOC home medical equipment (HME) panel. One of six panels convened, the HME Panel included rehab, respiratory, diabetic supplies, orthotics and prosthetics, and beneficiary organizations. George Taler, MD, Director of Long Term Care at Washington Hospital Center in Washington, DC, addressed physician concerns. Sharon Baranoski, MSN, RN, CWOCN, FAAN, Administrator, Home Health, Silver Cross Hospital, Joliet, Ill., provided the clinician viewpoint. Thomas Jeffers, Director of Government Affairs for Hill-Rom Company, Batesville, Ind., offered the manufacturer and provider perspective. Even though the CMS designated the panel’s focus as HME, most of the presentation addressed support surfaces. This topic involves a complex mix of medical devices, service, and care that, according to Alliance representatives, renders these products inappropriate for competitive bidding. Including support surfaces in a competitive bidding program could decrease reimbursement and subsequently force providers to reduce services. That, in turn, could reduce patient compliance and outcomes, resulting in more costly emergency room and hospital visits.

    With regard to the home care physician’s concerns with competitive bidding, Dr. Taler stated that the physician has ultimate responsibility for prescribing equipment and ensuring patients get medically necessary products and services. The HME supplier interacts with the professional services staff, caregivers, and patients. Dr. Taler described the complexity of managing the wound care patient and the physician’s need to prescribe a wide range of support surfaces due to the diverse patient population; equipment and supplies should meet both the clinical and functional needs of the patient. He also noted the need to have access to niche providers of patient services and the need for documentation of care plan oversight and certificates of medical necessity. He warned that competitive bidding might place wound care patients at risk and that the price of failing to treat them appropriately was high — eg, increased use of emergency departments, avoidable hospitalizations, nursing home placements, and misspent personal and societal resources.

    Ms. Baranoski, addressing the importance of the clinician in establishing a comprehensive plan of care for patients in the home care setting and the need for appropriate home medical equipment, said competitive bidding could limit patient access to appropriate home medical equipment and to quality providers of necessary services. Ms. Baranoski posed the following concerns to the PAOC:
  • Will there be enough providers both in rural and metropolitan areas to provide the services patients need?
  • Will bid-winning providers simply drop-ship equipment or will they deliver products and be properly trained in set-up, patient care instructions, follow-up, maintenance needs, and safety?
  • Will bid-winning suppliers only deliver equipment they have in stock versus what is ordered?

    Representing the the provider/manufacturer point of view, Mr. Jeffers spoke about important service components for patients needing wound care, which include:
   • Admission process
  • Appropriate product selection
   • Delivery expertise
  • Adherence to quality standards
   • Clinical expertise.

    He stressed that competitive bidding could threaten the relationship between the patient and providers who have developed expertise in wound care and have an extensive services component for Medicare patients. He also noted that the documentation challenges associated with the demonstration of medical necessity must be considered in the bid construct.

    Concerns relevant to manufacturers include:
  • Competitive bidding could potentially stifle innovation. A downward spiral of reimbursement would discourage new development
   • Support surface HCPCS codes need to be expanded — current codes include a vast array of products of varying quality, technology, function, and efficacy. Not expanding the number of HCPCS codes could result in adoption of the least expensive offering, which could have implications for patient access, clinical outcome, and quality of products bid.

    The Panelists concluded that in order to provide Medicare beneficiaries with continued quality and support, care must be taken to ensure that pricing is not the only consideration in the bid process.
At the end of the 2-day presentation, CMS Director of Medicare Management Herb Kuhn complemented the speakers for the “richness” of their presentations and said he was impressed with their content. He noted that another PAOC meeting would be held during the comment period when the proposed rule was published.

    In addition to the Panelists’ presentations, the newly released draft of quality standards for suppliers was discussed. Eventually, all DMEPOS suppliers who want to participate in Medicare will have to meet quality standards — including the business and product-specific requirement — which will be applied by CMS-approved accrediting bodies as mandated under the Medicare Modernization Act. The 60-day comment period ends November 28, 2005. Comments can be sent to: DMEPOS_Quality_Standards_Public_Comments@cms.hhs.gov.

    More information about the meeting, the presentations, and quality standards can be found at: http://www.cms.hhs.gov/suppliers/dmepos/compbid/paoc.asp.