Sunday, June 23, 2013

Medicare's National Mail Order Program for Diabetic Testing Supplies

On July 1, 2013, Medicare Part B will implement a national mail-order competitive bidding program specifically for diabetic testing supplies.  The program applies to all zip codes in the 50 United States, the District of Columbia, Puerto Rico, U.S. Virgin Islands, Guam and American Samoa. Once implemented, beneficiaries in traditional Medicare will purchase diabetic testing supplies using a mail order option or a non-mail order option.  

Included Supplies
Equipment such as blood glucose monitors, blood glucose test strips, lancet devices, lancet, and glucose control solutions for checking the accuracy of testing equipment and test strips and other Medicare Part B covered diabetic testing supplies are included in the national mail-order program.  However, Medicare Part D-covered supplies such as syringes, needles and inhaled insulin devices are not included in the national mail-order program.

Mail-Order Options
Under the national mail-order competitive bid program, traditional Medicare beneficiaries will purchase their diabetic testing supplies through a national mail-order contract supplier ("Mail Order Option") or in person from any Medicare-enrolled supplier of non-Medicare testing supplies ("Non-Mail Order Option").  Mail-order supplies will be shipped directly from the supplier to the beneficiary through a service such as United States Postal Service, Federal Express, the United Parcel Service or a mail-order contract supplier's delivery service. Beneficiaries can find suppliers at http://www.medicare.gov/supplierdirectory/search.html.  

Medicare Part B will reimburse mail-order deliveries provided that they are delivered directly from the supplier to a beneficiary's residence.  Beneficiaries who select the Mail-Order Option cannot have diabetic testing supplies shipped to a pharmacy and then have the pharmacy deliver the supplies to the beneficiary. If this is attempted, Medicare Part B will not reimburse the supplier or the pharmacy.

Unfortunately, this means that beneficiaries no longer have the option of delivery from a local vendor even if the local business delivers other items to them.

Congress established strict reimbursement and delivery rules for the purchase and receipt of diabetic testing supplies and made distinctions between mail-order and non-mail order options (both as to cost and access). As discussed below, non-mail order supplies may be more costly to the beneficiary.  Distinguishing between the two options is intended to prevent suppliers who did not win bids (or did not participate in the bidding competition) from circumventing the competitive bidding program and assures that the Medicare program realizes the savings afforded by the competitive bidding program.

Cost
Beneficiaries who purchase diabetic testing supplies using the Mail Order Option or the Non-Mail Order Option may be charged different amounts. Different charges are possible because Mail Order suppliers must accept assignment-based purchases and Non-Mail Order suppliers have the option to accept assignment-based purchases. Non-Mail Order suppliers also have the option to enroll in Medicare. A supplier who accepts assignment-based purchases can charge only the Medicare approved amount for the supplies. Suppliers who do not accept assignment-based purchases may charge a different amount than suppliers who do accept assignment-based purchases. Suppliers who are not enrolled in Medicare may not bill Medicare for supplies a beneficiary purchases.

A beneficiary's payment will depend on which type of supplier is select.  The four types are:
  1. Mail-Order supplier
  2. Non-Mail-Order supplier, Medicare enrolled and accepts Assignment
  3. Non-Mail-Order supplier, Medicare enrolled and does not accept Assignment
  4. Non-Mail-Order supplier, not Medicare enrolled and does not accept Assignment  
A Mail-Order supplier must accept assignment and must be enrolled in Medicare. A beneficiary who purchases supplies from a Mail-Order supplier cannot be charged more than 20% coinsurance and any unmet deductible. For example, a beneficiary purchases $100 worth of diabetic testing supplies based on Medicare's reasonable charge or fee schedule amount. The supplier may charge the beneficiary only $20 (20% coinsurance) and any unmet deductible.

A Non-Mail-Order supplier that is enrolled in Medicare and accepts Assignment cannot charge a beneficiary more than 20% coinsurance and any unmet deductible. This is the same amount that Mail-Order suppliers must charge. For example, a beneficiary purchases $100 worth of diabetic testing supplies based on Medicare's reasonable charge amount or fee schedule amount. The supplier may charge the beneficiary only $20 (20% coinsurance) and any unmet deductible.

A Non-Mail Order supplier that is enrolled in Medicare who does not accept Assignment is not subject to the limiting charge law (which prohibits some suppliers from charging more than 115% above Medicare's reasonable charge or fee schedule amount) and can charge a beneficiary its full rate for the supplies. Likewise, a Non-Mail Order supplier that is not enrolled in Medicare and who does not accept Assignment is not subject to the limiting charge law.

Beneficiaries receiving Non-Mail-Order supplies should confirm with their vendor (such as a local pharmacy) that they accept Medicare Assignment to ensure that they will not be charged more than Medicare's reasonable charge calculation or fee schedule amount. Beneficiaries receiving Non-Mail-Order supplies should also confirm with their vendor/pharmacy that they are enrolled in Medicare to ensure that Medicare will pay for part of the supplies ordered.

For more information, including:

Conclusion
Advocates will need to explain the two mail-order options to Part B beneficiaries to ensure that beneficiaries are fully informed of their options. Also, advocates will need to reiterate that those who choose the non-mail order option should call their pharmacy or other vendor to make sure they accept Medicare assignment.



Alert Correction - In the Weekly Alert for June 20, 2013, "Medicare's National Mail Order Program for Diabetic Testing Supplies," we mistakenly included glucose monitors in the list of diabetic testing supplies subject to the DMEPOS mail order competitive bidding program.  The monitors are not included.

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