CRE’s comments to OIRA on CMS’ Information Collection Request for their Durable Medical Equipment bidding program is attached here.
Key conclusions in CRE’s comments are:
• Practical Utility. The ICR does meet the Paperwork Reduction Act’s practical utility requirements since it does not meet the MMA’s goal of obtaining home medical equipment and services at competitive prices.
• Utility and Transparency. The ICR does not meet the Data (Information) Quality Act’s utility and influential information requirements because it does not use accepted models and a transparent methodology.
• Small Business and Job Loss. CMS’ use of the data from the ICR has been demonstrated to reduce the small business share of the Medicare home medical equipment market by almost half from CMS projections for 2012 and radically reduces the number of Medicare supplies by 85-95%.