{"id":35616,"date":"2014-03-27T08:31:44","date_gmt":"2014-03-27T12:31:44","guid":{"rendered":"http:\/\/asweetlife.org\/?post_type=feature&p=35616"},"modified":"2016-11-22T05:36:20","modified_gmt":"2016-11-22T10:36:20","slug":"speak-out-against-competitive-bidding-for-insulin-pumps-urgent-action-required","status":"publish","type":"post","link":"https:\/\/asweetlife.org\/?p=35616","title":{"rendered":"Stop Competitive Bidding for Insulin Pumps"},"content":{"rendered":"
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.)\u00a0<\/em><\/div>\n
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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.<\/em><\/div>\n
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Read the Comments Here:<\/em><\/div>\n
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http:\/\/www.regulations.gov\/#!docketBrowser;rpp=50;po=0;dct=PS;D=CMS-2014-0029;refD=CMS-2014-0029-0001<\/a><\/em><\/p>\n

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As my recent attempt to \u201cbring sexy back\u201d to the subject of the <\/span>FDA\u2019s draft guidance on diabetic test strips<\/a> 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).<\/span><\/div>\n<\/div>\n<\/div>\n

So watch out: this is a piece about Medicare.<\/p>\n

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 \u2013 and how much it\u2019s 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.<\/p>\n

So here\u2019s 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<\/a> for more details on that.)<\/p>\n

\u201cCompetitive bidding\u201d is a Congressionally mandated program meant to reduce the cost of Medicare and Medicaid, in this case by cutting reimbursement rates for DMEPOS<\/a> (the category, short for \u201cDurable Medical Equipment, Prosthetics, Orthotics and Supplies,\u201d in which they place insulin pumps).\u00a0 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.<\/p>\n

Now, reducing the cost of Medicare and Medicaid is important \u2013 especially given some of the truly ludicrous abuse and overcharging<\/a> 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\u2019s 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 \u2013 let alone the miniscule number of people on Medicare who actually have access to an insulin pump, thanks to Medicare\u2019s restrictive policies<\/a> — it appears that insulin pumps really should not have been included in competitive bidding to begin with.<\/p>\n

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.<\/em><\/p>\n

Because let\u2019s put it this way: if competitive bidding lowers reimbursement rates too greatly, we are never going to get to an artificial pancreas.<\/strong><\/p>\n

Lucky for us, CMS is currently encouraging public comment<\/a> on future rounds of the competitive bidding program, including for insulin pumps. The deadline is this Friday, March 28 at 11:59 PM EST. <\/strong>Here is what we need to say (feel free to cut and paste \u2013 and you can submit it here<\/a>, at the \u201csubmit a comment\u201d link on the right):<\/p>\n

[Editor’s note: While the official comment period has closed, you can still add comments.]<\/strong><\/p>\n

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  1. Insulin pumps should not be included in competitive bidding. (Indeed, they\u2019re not even included in this official description<\/a> 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.)<\/li>\n
  2. CMS states that \u201cTo date, monitoring data have shown a successful implementation<\/a> with very few complaints and no negative impact on beneficiary health status.\u201d However, not only was competitive bidding for insulin pumps only begun on January 1, 2014 \u2013 making it far too early to determine the impact on beneficiary health status \u2013 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\u2019s 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.)<\/li>\n
  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 <\/em>the pump; it should not be issued on a rental basis.<\/li>\n
  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 \u2013 or requirement \u2013 in place to insure that suppliers are actually providing the products they promised to supply in their winning bids.<\/li>\n<\/ol>\n

    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<\/a> by 11:59 p.m., Friday, March 28:<\/p>\n