Competitive Bidding Networks for Small DMEPOS Suppliers

By William Popomaronis, R.Ph.

CMS has clearly defined the requirements for small suppliers to bid collectively on the DMEPOS product categories like diabetes testing supplies.

Operationally, the network must conform to CMS's "Opportunity for Network Guidelines" detailed in pages 113-118 of CMS's proposed rule 1270-P.

Key network requirements include:

  1. Separate legal entity must be created
  2. The legal entity is responsible for billing and collections
  3. Executed performance agreements with supplier (subcontractors) required
  4. Each subcontractor must be accredited and can only join one network
  5. Subcontractor cannot bid independently, if bidding through a network
  6. The network can't be anticompetitive (defined as having greater than 20 percent market share)

VGM the DMEPOS supplier buying group based in Waterloo, Iowa, has submitted an application to CMS to form a competitive bidding network. The application, made in November 2006, in the name of Homecare Providers of America, officially starts the paperwork process required for its members to form and bid as a network. Members would be able to select participation levels, product types, and geographic service levels within the bid areas as a "network primary supplier," according to the buying group. VGM said that it expects to operate programs in each competitive bidding area.

Look to your buying group or wholesalers as others consider forming bidding networks on behalf of their members and customers.

 
 
 

William Popomaronis, R.Ph., is vice president, long term and home health care services for the National Community Pharmacists Association (NCPA). He is also the only pharmacist member of Medicare’s Program Advisory and Oversight Committee (PAOC), which provides advice on the development and implementation of the DME Competitive Acquisition Program.

 
 
  Bayer HealthCare, Diabetes Care, has underwritten the costs of this communication. The information expressed in this communication are the views of NCPA. Bayer is not responsible for the accuracy of the information expressed in this communication. Any questions related to DME Accreditation and/or Competitive Bidding for DMEPOS should be directed to the Centers for Medicare and Medicaid Services or NCPA.