Excluding Urologicals and Ostomy from Competitive Bidding

Background

During the 1999 and 2001 Competitive Bidding demonstrations in Polk County, Florida, urological supplies were included in the Competitive Bidding program pilot, which government agencies concluded that “the category of urological supplies is not as well suited for Competitive Bidding” and advised against including it in future rounds.  However, recent references to expanding the Competitive Bidding program to include urological and ostomy supplies have been included in the President’s Budget and MedPAC recommendations.  

Why Ostomy & Urologicals are Not Well Suited for CB

Prescribed ostomy and urological products are used to manage medical conditions that interfere with or do not allow for normal bowel and/or bladder functions.  These product categories are broad and extremely complex, are not easily interchangeable, and are not one-size-fits-all.  The complexity of product is needed to meet the distinct and highly variable needs of patients to appropriately manage biological waste.  Consumer advocacy groups join HME stakeholders in strongly supporting the exclusion of these products from Competitive Bidding due to the harmful impact it would have on end users.

Numerous CMS reports point to the limited savings potential and “deleterious effect on product selection” that the Competitive Bidding program could have in spite of some products being better suited for individuals than others within a single HCPCS code.  CMS’ evaluation of urologicals in the Competitive Bidding Demonstrations determined that it had a negative impact on quality, access, and support, acknowledged discrepancies in reimbursement for the wide variety of products within a HCPC code, and concluded that urologicals were not appropriate for Competitive Bidding.

The HME Industry partnered with United Ostomy Association of America, United Spinal, and Spina Bifida Association to create a White Paper articulating these issues and continues to meet with legislators and regulatory agencies to educate on the importance of not expanding Competitive Bidding to include urologicals and ostomy products.  Instead, they recommend working with provider and patient groups to ensure that changes in policy do not adversely affect beneficiaries that require these supplies. AAHomecare sent a comprehensive letter to MedPAC in response to the June 2018 MedPAC report, articulating why the their recommendations should not be implemented.

Resources

• AAH Issue Brief: Competitive Bidding Should Not Expand to Include Ostomy & Urological Supplies '18
• MedPAC Report on Issues in Medicare's medical device payment policies
• Multi-Stakeholder White Paper Why CB Should Not Expand to Ostomy & Urological Supplies ’18 
• HHS Final Evaluation of CB Demonstration ’04
• CMS 1st Year Evaluation of CB Demonstration ’00