As discussed previously, a repeal of the device tax faces longish odds. Opponents of the tax have punted to a suspension of the tax as was disclosed by a letter from nearly 20 members of the U.S. Senate, a move purportedly prompted by the short turn-around from the date of the IRS’s final rule to the effective date of the tax. Despite the disclaimers, it’s important to point out that you clearly don’t believe a repeal has any chance in the short term if you’re arguing for a suspension. So let’s ask ourselves what sort of headwinds the device tax...
The Centers for Medicare & Medicaid Services has published a draft guidance for the new framework for coverage with evidence development, or CED, a very interesting framework indeed. Following is a list of some fascinating tidbits from the draft guidance. Interesting item #1: The passage stating that CMS is examining the question of “whether local contractors should have the discretion to apply CED in local coverage” is pretty close to an earthquake. I’m assuming that most CED trials will have to span more than one Medicare carrier’s jurisdiction, which suggests a patchwork of CED coverage or a need to get...
