Response to 60-day Comment

CMS-R-263 60-Day Comments and CMS Responses

Comment 1:

Commenter has two general asks in their letter. The first ask is to fill out the form prior to the Site Visit. The commenter states the form is overly burdensome for suppliers and that the information requested on the form is repetitive to information requested in the Medicare Provider Enrollment, Chain, and Ownership System (PECOS).

The second ask is to reinstate a form that the previous site visit contractor used. The form is referred to as the, “RA-SACU Site Visit Acknowledgment Form.” The commenter states the purpose of the form was to be signed by the surveyor and the supplier and to attest to the site visit being completed.

CMS Response:

While we appreciate the commenter’s concerns about supplier burden, the form is filled out entirely by the National Site Visit Contractors (NSVCs). The data collected on the form is collected in order to verify information submitted by the supplier via enrollment. While the data might seem repetitive, the purpose is to verify the information as well as to verify the supplier’s compliance with the supplier standards as cited in 42 CFR 424.57(c).

As for the Acknowledgement form, we appreciate the commenter’s suggestion. We will not be reinstating this process because the completion of a site visit does not necessarily equate to full compliance of the DMEPOS supplier standards, and thus, enrollment into the Medicare program. The final enrollment approval letter serves this purpose.

Comment 2:

The commenter expresses concerns about people who are not citizens of the United States using Medicaid.

CMS Response:

This comment is outside the scope of this information collection.

Comment 3:

The commenter expresses concerns with the use of lidocaine and epinephrin and the adverse outcomes related to those drugs.

CMS Response:

This comment is outside the scope of this information collection.