We’ve received numerous calls relative to licensing for the Round Two program.  To begin, we have the links for licensure information on our Web-site at www.vgmncbservices.com.  Click on the upper tab “CBAs” and select your areas of interest from the interactive map.  You will see a Licensure link on the left side of the page. 

But the information within the links doesn’t necessarily answer the plethora of questions with regard to multi-state bidding.  Many of the CBAs cross state lines.  Some states require specific licensure; some none.  Some states do NOT require an out of state entity to obtain a license to service patients within the state.  And so on and so on. 

With that said, let me de-identify an actual bidder who expressed frustration with unclear direction from the CBIC regarding multiple state/CBA bidding and the associated “Form A”.  Below this section  I will then reprint certain clarifications from Palmetto’s Elaine Hensley.  Elaine is a great asset to VGM for her timely responses to our concerns; she is Chief Ombudsman of the CBIC. 

Let’s start with this reprint

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Mark,

Not real sure how to explain problems with Form A but will try to give you’re the short version.

I am bidding in 4 CBA’s, and have 6 Locations that will service patients. TN requires an HME license, AL requires the HME and Pharmacy License and Augusta is in GA and SC and SC requires Non-Resident Med Gas/DME licenses.

I have set up my corporate location as the primary identifying information and business organization (the PTAN that was used to register), commonly owned or commonly controlled, multiple locations, corporation, licensed in 4 States, bidding 8 categories excluding mail order, and bidding 4 CBA’s (Atlanta, Augusta, Chattanooga, Birmingham).

Everything was good until I tried to add additional locations that would serve all CBA’s. The first real problem I had was that when I got to the “add license for additional location” that you are required to enter, there is a drop down screen where you choose “licensure state” and all 4 states drop down for choice. I selected the state for the location that was appropriate and added the appropriate license info and added licensure and saved as prompted, then went to next locations.

When I had completed all locations the status for primary PTAN indicated COMPLETE and all additional locations status was INCOMPLETE . When I tried to modify the individual locations it indicated no license information available although there was licensing information populated on the screen and when printed appeared on paper as well.  After calling the CBIC for help I was told that the licensure for each state that was indicated on the primary had to be completed for each additional location before it would allow to “complete”. I added all licensure info for all 4 states for each additional location and sure enough all 5 additional locations status indicated COMPLETE.

I called the CBIC again and after about 40 minutes trying to describe situation was finally told to add licensure for all 4 states for all additional locations.  I also started thinking that the licensure info I had just entered would not match if copies of licenses were requested (ie: TN license attached to TN address and PTAN and not Atlanta, Birmingham etc. same with Alabama license and SC license). I called CBIC again  this morning and was directed to go back into modify form A and the licensing requirement for additional Locations and simply choose each state but to put NA if there was no requirement or it was not required for that state for that location… which also worked and status stayed PENDING APPROVAL. I am still NOT sure if I need to indicate only state required licensure info or if I need to indicate all city, county and state business licenses as well. Needless to say I have 999 characters and plenty of room so I went ahead and put everything in.

 I am told I can still go back and MODIFY form A up until 3/31/2102 so not to panic.

One other thing that I realized is that all licenses have to of file with the NSC and updated in PECOS too.

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(Response from Elaine…)

Mark,

My questions for this HME is do they intend to service every CBA with every location they’ve listed on their bid or will each location only service the state in which it exists?  Let’s use the Chattanooga CBA as an example:  Tennessee locations service only Tennessee beneficiaries and Georgia locations service only Georgia.

In DBidS, bidders are only required to indicate the applicable license(s) for the product categories and CBAs (states) in which they bid.  Suppliers do not need to enter the city, county, and state business licensure information for bidding purposes.  However,  that information is required in order to comply with Standard #1 of the Medicare DMEPOS Supplier Standards, which reads, “A supplier must be in compliance with all applicable federal and state licensure and regulatory requirements.”  Per page 3 of the Round 2 Request for Bids:

Bidding suppliers must ensure that copies of all applicable state licenses are RECEIVED by the NSC on or before May 1, 2012. Bids will be disqualified if a bidder does not meet all state licensure requirements for the applicable product categories and for every state in a CBA. Every supplier location is responsible for having all applicable license(s) for each state in which it provides services. For a multi-state CBA, the bidder must collectively have all applicable license(s) for every state in the CBA. Each location is not required to have licenses for every state in the CBA as long as each state has a bidding location licensed for the product category.

 Please let me know if there are additional questions.

 Elaine

 Elaine Hensley, Chief Ombudsman Palmetto GBA DMEPOS Competitive Bidding Implementation Contractor

Elaine.Hensley@PalmettoGBA.com

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Hope this helps some!