Every day it seems we are bombarded with changes from Medicare. I cannot remember a day that has gone by that I have not opened up multiple e-mail messages from each DMERC, or more recently, the new DME Medicare Administrative Contractors, with updates and policy changes.
There is always a new HCPCS code being issued, a change to a fee schedule or a policy revision to look at. The amount of information to review and retain is enormous. I am just glad that it is sent to me automatically by the listserv service that each DMERC and DME MAC offers. If I had to go out and find it each day, I certainly would spend all day on their Web sites. You can subscribe to the listservs at the following Web sites for each region:
DME MAC Jursidiction A, National Heritage Insurance Company, www.medicarenhic.com;
DME MAC Jursidiction B, AdminaStar Federal, www.adminastar.com;
DMERC Region C, Palmetto GBA, www.palmettogba.com (note that the new DME MAC contractor, which should assume duties later this year, has yet to be named);
DMERC Region D, Cigna Government Services, www.cignagovernmentservices.com (note that in October, services will transfer to the new DME MAC, Noridian Administrative Services, www.noridianmedicare.com).
There is another Web site that some people may not visit very often, but it is critical in the whole process of policy-making: the CMS Web site, www.cms.hhs.gov.
The reason this government site is so important is because the policy changes are made by CMS and passed along to the DME MACs to implement.
You also can subscribe to a listserv at CMS that will inform you of policy changes prior to implementation at the DME MACs, allowing you to better prepare.
To sign up for the CMS coverage listserv, as well as an array of other listservs offered by the agency, visit https://list.nih.gov.
An advantage of subscribing to the CMS listserv is that you will get notice of proposed policy changes.
This is critical because when a new policy will be initiated or an existing policy is going to be changed, you will be given a period of time (typically 30 to 60 days) to comment on the proposed policy. Making comments is very easy to do, and it can be done on the Internet or via regular mail.
Go to www.cms.hhs.gov/eRulemaking/01_Overview.asp, which is the e-rulemaking page, and you can click on the link that will allow you to make a comment on the proposed policy.
When you do make comments, remember the following:
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Refer to the regulation, title and CMS number listed at the beginning of the regulation.
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Clearly indicate whether you are for or against the proposed regulation or some part of it, and indicate why.
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Include copies (references) to articles that support your comments. If an article or reference is in a foreign language, it must be accompanied by an English translation that is verified to be accurate, and a copy of the original publication should accompany translations.
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Delete names or other information that would identify patients.
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Deliver comments before 5 p.m. on the last day of the comment period.
It is critical that we, as an industry, comment on Medicare's proposed changes. These are the policies that determine how we run our businesses.
In general, HME providers have not traditionally been very involved in this process, and you can see the results of non-action by the industry: the 36-month cap on oxygen rentals, the elimination of capped rental and competitive bidding. The list goes on and on.
I am not saying that by logging on to the CMS Web site and submitting comments we could have changed all of these things. But I am saying that if we are heard as a unified voice, our opinions will be considered when the powers that be make these decisions that affect our everyday business. Speak out and be heard. You can make a difference.
Jane Bunch is vice president, HME consulting, for Atlanta-based CareCentric. A reimbursement specialist, Bunch delivers educational seminars worldwide, helps develop corporate compliance plans and serves as a consultant for fraud and abuse cases. She can be reached at 678/264-4495 or via e-mail at jane.bunch@carecentric.com.
