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CMS’ Form C Limitations Make Access to Quality Goods

The publicized mantra for Medicare Part B’s competitive bidding program has been to reduce expenditures while maintaining quality and ensuring beneficiary access to the goods and services that they need. One of the frequently raised questions regarding this is:

How will CMS ensure that beneficiaries will have access to the goods they need; and, how will CMS ensure that the goods provided are of equivalent quality to what beneficiaries from outside of the competitive bidding areas, or covered by other payers, are receiving?

As a means to address these concerns CMS created a “Form C Quarterly Report” through which winning bidders must report the manufacturer, make and model of goods provided to beneficiaries in the bid areas. CMS’ contractor, the CBIC (Competitive Bidding Implementation Carrier), has a considerable amount of information on its website regarding Form C. On the CBIC website it states that the “Form C Quarterly Report” is to “provide CMS with information to monitor the program to ensure beneficiaries have access to and are receiving quality items.” Further, instructions included on the CBIC site stress that bid winners are “responsible for providing the model, manufacturer and model number for the top 80 percent Healthcare Common Procedure Coding System (HCPCS) codes in the product category.”

The CBIC website provides a tool to identify the codes which must be reported by the Competitive Bid Area (CBA) and competitive bidding product category: (

When using this tool for the competitive bidding product category of “standard power wheelchairs and accessories” it indicates that winning bidders must provide manufacturer, make and model information for three HCPCS codes, K0822, K0823 and K0825.

However, the competitive bidding product category for standard power wheelchairs and accessories contains 106 HCPCS codes! These three codes only represent 2.8% of the total codes in the product category. How does this correlate with the requirement that the bid winners must report for the top 80% of codes within the category? The only explanation that appears to resolve this apparent conflict is that these three codes represent over 80% of the total expenditure within the category.

This really seems to reinforce, rather than address, the initial concern. Consider the following:

  • If only three codes represent so much of the total expenditure then why is it necessary, or even appropriate, to include the other 103 codes in competitive bidding?
  • Even if all the other items in the standard power wheelchair product category represent a small portion of the total expenditure, it is still critically important the beneficiaries have access to the goods they need and that the products they are provided are of an acceptable quality.
  • This product category contains:
    • Products intended to protect the beneficiary’s skin from breakdown.
    • Products designed to address the positioning and stability needs of the beneficiary.
    • A myriad of products that may need to be make and model specific in order to fit on the specific power wheelchair.

How will Form C ensure that beneficiaries have access to quality products in these critical areas?

Does this illustrate the need for competitive bidding rules to be modified to focus only on those items that have the greatest expenditures and the greatest opportunity for savings? Why should beneficiaries’ access to the quality goods that they need be placed at risk, especially when the potential opportunity for savings is very small?


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