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VGM Creates Templates for IFR Comment Period

Posted on in Legislation, Government and Advocacy

Within the release announcement of the interim final rule, which will provide seven months of relief to rural and non-contiguous suppliers, CMS has said they are soliciting comments for rates in 2019 and beyond. It will be crucial to have an abundance of comments from independent suppliers in determining the rates for after Dec. 31, 2018. Click here to view the CMS Fact Sheet on the IFR.

VGM has created a general template for suppliers to use when crafting their comments. Suppliers may download the template here which includes suggested commentary. A few brief, key points that we encourage suppliers to include in their own comments are:

  • Future policy decisions must include all non-bid areas who serve many patients in “non-rural” areas as deemed by CMS, but still travel a long distance to serve patients.
  • The adjusted fee schedule that non-bid (non-rural) suppliers are forced to continue providing care at is unsustainable and led to a dramatic decrease in the number of suppliers able to stay in business.
  • The oxygen “double dip,” because of the budget neutrality offset, has pushed oxygen reimbursement levels below the SPA in areas and is an unfair, dangerous regulation that applies two payment methodologies to one product category.
  • Lastly, that the CMS patient complaint and access monitoring is not capturing patient complaints, and that many patients are either paying out of pocket or going without the care. We encourage providers to give any examples of patients having to wait weeks to receive equipment, improper denials/audits, etc.

Comments to CMS are due by 5 p.m. EDT, July 9, 2018. Comments may be submitted on regulations.gov by clicking here.