Kevin Corcoran CA

In your proposal to increase supplier enrollment safeguards, you state ??At ? 424.57 (c)(29), we are proposing a new standard that specifies that the supplier is prohibited from sharing a practice location with another Medicare supplier. DMEPOS suppliers may not share a practice location with any other supplier, including a physician/physician group or another DMEPOS supplier.? We believe that this proposal would be incompatible with the common situation where an optical dispensary is located in an ophthalmologist?s or optometrist?s office. It is frequently the case that Medicare beneficiaries fill the physician?s prescription for post- cataract eyeglasses or contact lenses in the optical dispensary owned and/or operated by the same physician. If implemented, your new supplier standard would either bar opticians from serving Medicare beneficiaries referred by their employers or provide a strong motivation for opticians to opt out of Medicare. In either case, access to the services of opticians for Medicare beneficiaries would be significantly reduced. In the beginning of your proposal, you state ??that the vast majority of DMEPOS suppliers are small entities (based on Medicare reimbursement alone).? For the sake of reference, annual sales of eyeglasses and contact lenses in the United States are about $16 billion and $2 billion respectively (Source: Jobson Publishing LLC). By our own survey and computation, the Medicare program?s aggregate annual reimbursements for post-cataract eyeglasses is estimated to be less than $200 million or about 1% of that business. Consequently, CMS should not infer the size of an optical dispensary based on the business it does with Medicare.