Anonymous-DC

Document ID: CMS-2011-0045-0005
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: May 31 2011, at 12:00 AM Eastern Daylight Time
Date Posted: June 3 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: April 4 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: June 3 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80e38ac0
View Document:

This is comment on Proposed Rule

Medicare Program: Revisions to Durable Medical Equipment, Prosthetics, Orthotics, and Supplies Suppliers Safeguards

View Comment

Rather than using data from March 2008 to develop the regulatory impact analysis, I recommend that Centers for Medicare and Medicaid Services (CMS) update the number of DMEPOS suppliers found in the Regulatory Impact Analysis using current data (e.g., June 2011). In this proposed rule, CMS states that approximately 20 percent of the suppliers of DMEPOS are located in rural areas; however, CMS is using March 2008 data to make this statement. Given the substantial changes to DMEPOS suppliers in the Medicare program since March 2008, including the implementation of surety bonds, accreditation, competitive bidding for certain jurisdictions, and new Federal Regulations published on August 27, 2010, I recommend that CMS provide an update regarding the number of DMEPOS suppliers located in rural areas.