Stop Competitive Bidding for Insulin Pumps

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UPDATE: When this article was published, there were approximately 30 public comments about competitive bidding on the CMS website. (The CMS document was about all sorts of durable medical equipment, not just insulin pumps.) 
 
As of today, there are 179 public comments on the CMS docket — and *at least* 78 of those comments are explicitly about insulin pumps! Check it out — it’s truly amazing. Thank you all so much for your participation and support. I hope that this serves as inspiration to CMS to open a dialogue with the patient community — and change its policies — around this extremely important issue.
 
Read the Comments Here:
http://www.regulations.gov/#!docketBrowser;rpp=50;po=0;dct=PS;D=CMS-2014-0029;refD=CMS-2014-0029-0001

 
As my recent attempt to “bring sexy back” to the subject of the FDA’s draft guidance on diabetic test strips might make clear, I have a habit of getting really interested in topics that might, upon first glance, appear to be monumentally boring (but which in reality are really important to anyone with diabetes).

So watch out: this is a piece about Medicare.

Or, more specifically, about insulin pumps and the Centers for Medicare and Medicaid Services (CMS), which is the organization that decides what Medicare is and is not going to cover – and how much it’s going to pay. This is an important organization for those of us under 65 to be aware of as well, not just because we will hopefully all live long enough to become Medicare recipients, but because the standards set by CMS often trickle down to the private insurance market.

So here’s the deal: CMS has recently rolled out the first stage of a competitive bidding programs for insulin pumps and other durable medical supplies. (This is separate from the recently implemented and highly controversial competitive bidding program for glucose meters and test strips — see stripsafely.com for more details on that.)

“Competitive bidding” is a Congressionally mandated program meant to reduce the cost of Medicare and Medicaid, in this case by cutting reimbursement rates for DMEPOS (the category, short for “Durable Medical Equipment, Prosthetics, Orthotics and Supplies,” in which they place insulin pumps).  In the areas in which competitive bidding for insulin pumps has taken effect so far, CMS has cut the reimbursement rates for insulin pumps and insulin pump supplies by approximately 15 and 20 percent, respectively. When competitive bidding for insulin pumps goes nationwide, as it is planned to do in the next few years, these rates are likely to be further cut. 

Now, reducing the cost of Medicare and Medicaid is important – especially given some of the truly ludicrous abuse and overcharging that goes on. There are cases of companies charging hundreds, even thousands of dollars for products that are basically interchangeable commodities, like bedpans or walkers. But as anyone who’s ever used an insulin pump knows, pumps are very much not interchangeable commodities (think about it: is an Omnipod interchangeable with an Animas Ping? If your insurance company forced you to switch, how would that affect your diabetes care?). In fact, if you look into the background of the program – let alone the miniscule number of people on Medicare who actually have access to an insulin pump, thanks to Medicare’s restrictive policies — it appears that insulin pumps really should not have been included in competitive bidding to begin with.

We in the diabetes community need to speak out to argue that a. insulin pumps should be removed from competitive bidding and b. that if they remain in the competitive bidding program, CMS must use a different process to determine reimbursement rates, so that cost-saving does not stifle innovation.

Because let’s put it this way: if competitive bidding lowers reimbursement rates too greatly, we are never going to get to an artificial pancreas.

Lucky for us, CMS is currently encouraging public comment on future rounds of the competitive bidding program, including for insulin pumps. The deadline is this Friday, March 28 at 11:59 PM EST. Here is what we need to say (feel free to cut and paste – and you can submit it here, at the “submit a comment” link on the right):

[Editor's note: While the official comment period has closed, you can still add comments.]

  1. Insulin pumps should not be included in competitive bidding. (Indeed, they’re not even included in this official description of competitive bidding.) Competitive bidding for Durable Medical Equipment was meant to reduce costs for products that are interchangeable commodities. Insulin pumps are not interchangeable (talk to any patient or diabetes educator!) and thus should not be included. (For example, personalized power wheelchairs are exempt from competitive bidding.) 
  2. CMS states that “To date, monitoring data have shown a successful implementation with very few complaints and no negative impact on beneficiary health status.” However, not only was competitive bidding for insulin pumps only begun on January 1, 2014 – making it far too early to determine the impact on beneficiary health status – but CMS is only looking at things like hospital admissions. Other factors, such as whether or not beneficiaries continue to have access to the particular pumps prescribed by their doctors, need to be included. (This is an issue that’s been highlighted by recent findings suggesting that many Medicare suppliers are not providing the diabetic glucose monitors and testing supplies that they promised in their initial Medicare bids.)
  3. If CMS continues, erroneously, to include insulin pumps in its competitive bidding program, then it must adopt a market-based approach to determine reimbursement rates. (At the moment, reimbursement rates are set using the lowest submitted bid as an anchor point, regardless of whether or not the supplier that submitted the low bid actually is able to fulfill it.) Additionally, patients should own the pump; it should not be issued on a rental basis.
  4. CMS needs to aggressively monitor whether or not DMEPOS (and blood glucose testing equipment) suppliers are actually providing the supplies and equipment that they included in their initial bid. Currently, CMS appears to have no oversight – or requirement – in place to insure that suppliers are actually providing the products they promised to supply in their winning bids.

 

In addition to these comments, there are also several areas that CMS is hoping that the public will weigh in on. If you have strong thoughts on any of the following, please include them. (DMEPOS refers to the category in which Medicare puts insulin pumps). Again, submit your comments here by 11:59 p.m., Friday, March 28:

  • Are there reasons why beneficiaries need to own – as opposed to rent – expensive durable medical equipment (including insulin pumps)?
  • Would there be any negative impacts associated with continuous bundled monthly payments for durable medical equipment (DME), including insulin pumps?
  • Do the costs of furnishing various DMEPOS items and services vary based on the geographic area in which they are furnished?
  • Do the costs of furnishing various DMEPOS items and services vary based on the size of the market served in terms of population and/or distance
  • Should an interim or different methodology be used to adjust payment amounts for items that have not yet been included in all competitive bidding program areas?
  • Are lump sum purchases and capped rental payment rules for DME and still needed? 

I know this may sound very technical and boring (and frankly, I don’t have much to say about their official questions, other than the first two), but it’s very important that our voices as patients be heard. To submit your comments (feel free to cut and paste these if you’d like), go to – wait for it! – this page. It would be useful to add a paragraph at the top explaining who you are and why this issue matters to you (and anything you have to say about the benefits of pump therapy over multiple daily injections, as well as why you don’t think insulin pumps are interchangeable with each other).

Please note that while the official comment period has closed, you can still add comments.

If you tweet about this (which I encourage you to do), please include @CMSGov and #WeAreNotWaiting.

You may now go back to the activities you naturally find enjoyable. 

 

Catherine Price is a regular contributor to ASweetLife.  She writes the blog Diabetes, Et Cetera.

Comments (6)

  1. jrasco525@gmail.com at

    There is no way that insulin pumps or continuous glucose monitors are interchangeable and the fact that so many people need them to survive should be reason enough to not be bidding for them.   My son was diagnosed at 15 months old and the 8-15 shots a day before the pump were unbearable.  Since his pump his A1C has dropped significantly and he is doing better than he has ever done.  Since I am a single mother of a two year old diabetic I am forced to stay at home with him and rely on Medicaid for his insurance coverage and if medicaid and medicare decide to make further cuts to the durable medical equipment he is able to have access too then I am not sure that my young son will survive. Instead of making cuts to diabetes supplies medicaid and medicare should be expanding what they will cover including the coverage of continuous glucose monitors for diabetics that are either unaware of highs and lows or are too young to communicate with their care givers about their highs and lows.
     

    Insulin pumps should not be included in competitive bidding. (Indeed, they’re not even included in this official description of competitive bidding.) Competitive bidding for Durable Medical Equipment was meant to reduce costs for products that are interchangeable commodities. Insulin pumps are not interchangeable (talk to any patient or diabetes educator!) and thus should not be included. (For example, personalized power wheelchairs are exempt from competitive bidding.) 
    CMS states that “To date, monitoring data have shown a successful implementation with very few complaints and no negative impact on beneficiary health status.” However, not only was competitive bidding for insulin pumps only begun on January 1, 2014 – making it far too early to determine the impact on beneficiary health status – but CMS is only looking at things like hospital admissions. Other factors, such as whether or not beneficiaries continue to have access to the particular pumps prescribed by their doctors, need to be included. (This is an issue that’s been highlighted by recent findings suggesting that many Medicare suppliers are not providing the diabetic glucose monitors and testing supplies that they promised in their initial Medicare bids.)
    If CMS continues, erroneously, to include insulin pumps in its competitive bidding program, then it must adopt a market-based approach to determine reimbursement rates. (At the moment, reimbursement rates are set using the lowest submitted bid as an anchor point, regardless of whether or not the supplier that submitted the low bid actually is able to fulfill it.) Additionally, patients should own the pump; it should not be issued on a rental basis.
    CMS needs to aggressively monitor whether or not DMEPOS (and blood glucose testing equipment) suppliers are actually providing the supplies and equipment that they included in their initial bid. Currently, CMS appears to have no oversight – or requirement – in place to insure that suppliers are actually providing the products they promised to supply in their winning bids.

     
     

  2. Neal Blomenkamp at

    To Whom it may concern,

    Insulin pumps should not be included in competitive bidding. (Indeed, they’re not even included in this official description of competitive bidding.) Competitive bidding for Durable Medical Equipment was meant to reduce costs for products that are interchangeable commodities. Insulin pumps are not interchangeable (talk to any patient or diabetes educator!) and thus should not be included. (For example, personalized power wheelchairs are exempt from competitive bidding.) 
    CMS states that “To date, monitoring data have shown a successful implementation with very few complaints and no negative impact on beneficiary health status.” However, not only was competitive bidding for insulin pumps only begun on January 1, 2014 – making it far too early to determine the impact on beneficiary health status – but CMS is only looking at things like hospital admissions. Other factors, such as whether or not beneficiaries continue to have access to the particular pumps prescribed by their doctors, need to be included. (This is an issue that’s been highlighted by recent findings suggesting that many Medicare suppliers are not providing the diabetic glucose monitors and testing supplies that they promised in their initial Medicare bids.)
    If CMS continues, erroneously, to include insulin pumps in its competitive bidding program, then it must adopt a market-based approach to determine reimbursement rates. (At the moment, reimbursement rates are set using the lowest submitted bid as an anchor point, regardless of whether or not the supplier that submitted the low bid actually is able to fulfill it.) Additionally, patients should own the pump; it should not be issued on a rental basis.
    CMS needs to aggressively monitor whether or not DMEPOS (and blood glucose testing equipment) suppliers are actually providing the supplies and equipment that they included in their initial bid. Currently, CMS appears to have no oversight – or requirement – in place to insure that suppliers are actually providing the products they promised to supply in their winning bids.

    Sincerely,
    Neal Blomenkamp 

    – See more at: http://asweetlife.org/feature/speak-out-against-competitive-bidding-for-insulin-pumps-urgent-action-required/#sthash.Ff0qsLDs.dpuf

  3. Bennet at

    Sent: Your Comment Tracking Number: 1jy-8b77-3664

  4. Jennie Broderick at

    Insulin pumps should not be included in competitive bidding. (Indeed, they’re not even included in this official description of competitive bidding.) Competitive bidding for Durable Medical Equipment was meant to reduce costs for products that are interchangeable commodities. Insulin pumps are not interchangeable (talk to any patient or diabetes educator!) and thus should not be included. (For example, personalized power wheelchairs are exempt from competitive bidding.) 
    CMS states that “To date, monitoring data have shown a successful implementation with very few complaints and no negative impact on beneficiary health status.” However, not only was competitive bidding for insulin pumps only begun on January 1, 2014 – making it far too early to determine the impact on beneficiary health status – but CMS is only looking at things like hospital admissions. Other factors, such as whether or not beneficiaries continue to have access to the particular pumps prescribed by their doctors, need to be included. (This is an issue that’s been highlighted by recent findings suggesting that many Medicare suppliers are not providing the diabetic glucose monitors and testing supplies that they promised in their initial Medicare bids.)
    If CMS continues, erroneously, to include insulin pumps in its competitive bidding program, then it must adopt a market-based approach to determine reimbursement rates. (At the moment, reimbursement rates are set using the lowest submitted bid as an anchor point, regardless of whether or not the supplier that submitted the low bid actually is able to fulfill it.) Additionally, patients should own the pump; it should not be issued on a rental basis.
    CMS needs to aggressively monitor whether or not DMEPOS (and blood glucose testing equipment) suppliers are actually providing the supplies and equipment that they included in their initial bid. Currently, CMS appears to have no oversight – or requirement – in place to insure that suppliers are actually providing the products they promised to supply in their winning bids.

    – See more at: http://asweetlife.org/feature/speak-out-against-competitive-bidding-for-insulin-pumps-urgent-action-required/#sthash.1yUGDf6h.dpuf

  5. Tamara Ragon at

    To Whom it may concern,

    Insulin pumps should not be included in competitive bidding. (Indeed, they’re not even included in this official description of competitive bidding.) Competitive bidding for Durable Medical Equipment was meant to reduce costs for products that are interchangeable commodities. Insulin pumps are not interchangeable (talk to any patient or diabetes educator!) and thus should not be included. (For example, personalized power wheelchairs are exempt from competitive bidding.) 
    CMS states that “To date, monitoring data have shown a successful implementation with very few complaints and no negative impact on beneficiary health status.” However, not only was competitive bidding for insulin pumps only begun on January 1, 2014 – making it far too early to determine the impact on beneficiary health status – but CMS is only looking at things like hospital admissions. Other factors, such as whether or not beneficiaries continue to have access to the particular pumps prescribed by their doctors, need to be included. (This is an issue that’s been highlighted by recent findings suggesting that many Medicare suppliers are not providing the diabetic glucose monitors and testing supplies that they promised in their initial Medicare bids.)
    If CMS continues, erroneously, to include insulin pumps in its competitive bidding program, then it must adopt a market-based approach to determine reimbursement rates. (At the moment, reimbursement rates are set using the lowest submitted bid as an anchor point, regardless of whether or not the supplier that submitted the low bid actually is able to fulfill it.) Additionally, patients should own the pump; it should not be issued on a rental basis.
    CMS needs to aggressively monitor whether or not DMEPOS (and blood glucose testing equipment) suppliers are actually providing the supplies and equipment that they included in their initial bid. Currently, CMS appears to have no oversight – or requirement – in place to insure that suppliers are actually providing the products they promised to supply in their winning bids.

    – See more at: http://asweetlife.org/feature/speak-out-against-competitive-bidding-for-insulin-pumps-urgent-action-required/#sthash.dWKYk9LQ.dpuf
    – See more at: http://asweetlife.org/feature/speak-out-against-competitive-bidding-for-insulin-pumps-urgent-action-required/#sthash.Ff0qsLDs.dpuf
     

  6. Dear all, these comments are fantastic — I’m so grateful!!! Check out some of them here: 
    http://www.regulations.gov/#!docketBrowser;rpp=25;po=0;dct=PS;D=CMS-2014-0029;refD=CMS-2014-0029-0001

    The comment period has officially closed, but if you’d like to submit them by mail (to the addresses in the link above) I don’t see how it could hurt. And I’ll keep you posted on other opportunities to make our views known. I’m so thankful to you all.  

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