Comments Submitted to CMS by the Medicare Payment Advisory Commission

The Commission concludes:

Competitive bidding for DMEPOS appears to be a promising way to improve the accuracy of  Medicare’s payments for these services.

FINANCIAL OUTLOOK: CMS RULE ON COMPETITIVE BIDDING

CRE has requested that a New York based proprietary trading firm, which specializes in the evaluation of equities, describe the impact the proposed rule will have on the stock prices of affected firms. An extraordinary action is needed because notwithstanding a wide range of actions taken to curtail the rule, CMS has failed to grasp the economic magnitude of its actions.

Comments Submitted to CMS by Bayer

Bayer makes two key arguments in their comments: 1) maintaining the pharmacist-patient relationship is crucial to the health of diabetes patients; and 2) implementing competitive bidding for diabetes supplies would significantly undermine this relationship.  Bayer cites two primary implications of harming the pharmacist-patient relationship: 1) reduced health quality for diabetic patients; and 2) increased expense to the federal government for treating more severe complications of diabetes

Comments Submitted to CMS by Byram

Comments Submitted to CMS by the Jefferson Health Group

This comment will  be of particular interest to economists. In making its arguments, Jefferson states:

” A study by Carnegie Mellon econmists, widely circulated within the industry cited the “franchise Fee” economic theory,  which noted that once bids were secured, that numerous small bidders will leave the industry, yielding at an oligopoly of power in each bid area, if not a defacto monopoly power to the award winners.”

Jefferson is making important macro arguments which should have a particular impact with regulators.

CMS Reimbursement Scooter Store

CMS Reimbursement Roche

CMS Reimbursement PBM

CMS Reimbursement INVA

CMS Reimbursement Cleveland Clinic