|Action||Update Section 940 Regarding Medicines, Drugs, Eyeglasses and Related Items|
|Comment Period||Ends 8/26/2016|
Virginia Hospital & Healthcare Association, on behalf of its hospital and health system members, respectfully submits these comments on the proposed fast-track regulations to update Section 940 regarding Medicines, Drugs, Eyeglasses and Related Items (Action 2197). An initial question is whether the documentation requirements in paragraph F.5 to certify exemption for purchases of durable medical equipment (DME) pursuant to paragraph F.1 are also intended to apply to purchases of prosthetics as those items are not specifically mentioned in paragraph F.5.
The primary concern, however, is that the documentation requirements in paragraph F.5 are administratively burdensome, especially in the case of a hospital or nursing home that makes a large volume of these purchases on behalf of specific patients in a given time period.
For these reasons, we encourage the agency to consider alternative approaches and greater flexibility in demonstrating application of the exemption to DME, and if applicable, prosthetics pursuant to paragraph F.1.
Thank you for this opportunity to comment. Any questions or requests for additional information can be directed to Brent Rawlings, Vice President & General Counsel, firstname.lastname@example.org (804)-965-1228.