VGM Meets with CMS to Discuss Concerns Related to Post-PHE

Published in Government Relations on March 28, 2022

VGM Government Relations recently met with CMS to discuss concerns about supplier requirements once the public health emergency (PHE) comes to an end.

We heard your concerns related to policy requirements and expectations after the PHE comes to an end and brought those to the attention of Provider Compliance Group for CMS’ Program Integrity. The discussion included a number of topics including providing plenty of notice (60 to 90 days) to the healthcare industry in preparation prior to the end of the PHE.

In addition, the discussion included concerns for the patients that are currently renting DME under the PHE waivers. Will these patients need to get qualified to meet policy coverage criteria, or will these patients fall under the grandfather method? While CMS representatives could not provide details, there was agreement that disruption of equipment use, medical necessity, and reimbursement should not occur for the patients and the suppliers.

Amongst the discussion, VGM’s Ronda Buhrmester and U.S. Rehab’s Dan Fedor raised concerns related to audits. With the various contractors that audit CMS claims, it was important that CMS is aware of the scrutiny that tends to fall on the DME suppliers. The claims using a PHE waiver (using the CR modifier and COVID-19 claim narrative) are a big concern for suppliers. The suppliers were also on the front lines collaborating with hospitals, nursing facilities, and physician clinics offering services to keep patients safe in their homes using home medical equipment.

While there were several topics of discussion related to policies and audits for post PHE, VGM’s Mark Higley provided data-related increases in staffing/wages, as well as acquisition costs.

The CMS staff appreciated the informative conversation with VGM, and are looking forward to future communications between both parties.


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  1. billing & reimbursement
  2. cms
  3. dmepos
  4. regulatory
  5. reimbursement
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  7. vgm government

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