Anonymous-CA

I would like to comment on the proposal that DMEPOS providers be open at least 30 hours per week. As I understand the need to curtail the fraud that is abundent in the medical medical supply business, the requirment that a supplier remain open for walk-in business does little, if anything to reduce fraud. This requirement will hurt the small DMEPOS supplier in two ways. First, many small mom-and-pop operations are run with just one or two poeple. It takes all of these one or two people to run the store, answer the phone, greet and help customers, sell merchandise, track expenses, etc. Along with these tasks comes the necessity to deliver items to patients. It it becomes necessary to reman at the facility for 30 hours per week, what time is left for the delivery of items? It may be a financial hardship for the small business owner to hire a staff member to deliver items. Secondly, the orginal operational plan of the business may not have been to be soley a "retail" store to beneficiaries. Many referrals come in through the telephone or fax, paperwork is completed and deliveries are made. I do agree that a facility should be open in case there is a need for a medicare beneficiary to present themselves, however; requiring a facility to be open at least 75% of the work week does not solve this issue when many of the beneficiaries are unable to get out of their homes. There are those businesses that were set up to be "retail" pharmacy type stores. This is their operating plan and this works for them. There are, however, those , that will not work under the same scenario. I feel that as long as the hours are posted and the provider is open during those hours that this should meet the requirment of CMS. If a provider wants to change the hours, then they should submit the changes to NSC as with any other change that is needed to be reported. This county was built on the backs of small businesses. To implement a requirement that puts small businesses at risk of closing makes no sense for either this country or, most im[portantly, to the medicare beneficiary who depends on many small DMEPOS's for their well being and quality of life.