Earlier in July, CMS released a proposed rule that makes some drastic changes to the Medicare Competitive Bidding Program (CBP). The CBP is flawed, and unfortunately the proposed rule that is meant to fix it would only make things worse for beneficiaries with diabetes.
What’s wrong with the CBP?
The CBP applies to certain durable medical equipment, including self-monitoring blood glucose supplies via mail order. When the CBP was created in 2011, the Centers for Medicare and Medicaid Services (CMS) thought that CBP would reduce out-of-pocket expenses for fee-for-services Medicare beneficiaries and would save the program money.
The CBP did drop prices (reimbursement for test strips dropped 72%), but over 95% of mail order diabetes suppliers were eliminated. This meant that beneficiaries had far fewer options for suppliers. CMS did not find there were any negative health consequences to having fewer suppliers, however, beneficiaries experienced difficulty in getting their supplies on time or at all.
Fast forward to 2014, when the National Minority Quality Forum (NMQF) performed a study to try to confirm CMS’s conclusions that Medicare patients with diabetes that are using insulin were not negatively impacted by implementation of the CBP. The NMQF study found that the number of beneficiaries who experienced disruption in receiving testing supplies rose by 58%. And if beneficiaries couldn’t get their testing supplies, then they couldn’t test their blood sugar, which could lead to serious consequences.
In the markets where CMS implemented the CBP, the NMQF study found that there were 42 additional deaths and twice as many hospitalizations as in unaffected markets. Clearly, the NMQF study found that CMS’s report (the one that said everything was fine) was incorrect.
Even with all this research that showed the CBP was harmful to beneficiaries with diabetes, in July 2013, CMS implemented CBP nationally for mail order supplies AND supplies obtained from retail channels. This move eliminated over 98% of suppliers that provide mail order diabetes supplies. Things haven’t gotten better since the program was implemented nationally. A preliminary study shows that disruption in supply availability has continued in all markets, and over ⅓ of beneficiaries on insulin are not acquiring testing supplies at all.
These beneficiaries are forced to make insulin treatment decisions
without knowing what their blood sugar is.
Why Doesn’t the Proposed Rule Fix the CBP?
The rule proposed in July of this year would, unfortunately, only make the problems worse. The rule would suspend the CBP on January 1, 2019. While the CBP does need to be reevaluated with a removal of diabetes testing supplies from competitive bidding altogether, the solution presented currently is not the answer.
When the program is suspended, the rule provides that any willing qualified supplier may continue to provide diabetes testing supplies. Suppliers of the best testing supplies will not be willing to operate “willingly” if they do not have more information about the return of the program, how they will be paid, and/or who they will be supplying long-term.
Because suppliers of the most accurate and trusted testing supplies will not continue supplying beneficiaries with their needed diabetes testing supplies, beneficiaries will lose access to testing supplies that they have been trained upon. Moreover, the likelihood of their existing mail order supplier continuing to provide these supplies is slim, creating yet another disruption of access.
What Can I Do?
CMS is accepting comments on the CBP proposed rule now. DPAC has done the hard work for you and written out a statement that you can alter and submit with just a few clicks. CMS needs to hear from patients that the competitive bidding program is not perfect, but stopping it under the proposed rule’s parameters makes it worse!