1/1/11: The Artificial Deadline

CMS’ January 1st start date for implementing Round 1 contracts is a timeframe of their own choosing.  Moreover, it is not a hard deadline.  The date is not set in statute and CMS’ website describes it as a “Target date” and noted that the  “Actual date will be announced through listserv notice.”

In light of the numerous problems with the Round 1 bidding, the most recent being the delay in announcing the bid winners, CMS needs to delay the January 1st implementation date.  The delay is needed, for among other reasons, because the delays in announcing the bid winners has resulted in an unacceptably short transition period for both providers and beneficiaries. To dely the date, CMS needs to do nothing more than send out a listserv announcement.

CMS should use the delay to accomplish at least three tasks:

1.  Determine what flaws in the agency’s bidding/bid review process resulted in firms being tentatively selected which raised “red flags” when a program integrity review was conducted. 

2.  Determine the impact on the program of bid process flaws which were discussed in the letter signed by over 160 academicians.

3.  Develop for public comment a proposal on how to correct the problems discussed above.

CMS’ priorities need to be the protection the protection of Medicare beneficiaries and taxpayers, not saving institutional face.  The agency should immediately demonstrate its recognition of CMS’ most essential responsibilities by delaying the January 1st starting date.