Pro-tip: Take advantage of covered document review process in Round 2021

By Cara Bachenheimer & Kim Brummett

Attention to detail is everything.
History is full of examples when overlooking small details led to much larger problems. From the leaning tower of Pisa, which was built on soft ground causing it to tilt, to a missing key that prevented the Titanic’s lookouts from getting binoculars to spot icebergs in the water, careful planning is critical.
So when it comes to Round 2021 of the Medicare Competitive Bidding Program (CBP), which opened for bidding in mid-July, bidders must pay close attention to cross their Ts and dot their Is.
The new bidding process is much improved from the CBP of the past. But being so different, it is vital that all suppliers who plan to submit a bid understand the new changes. As you examine how you might bid based on lead-item pricing, the clearing price rate setting, and new higher bid ceilings—among other important changes—don’t forget about the Process for Reviewing Covered Documents. 
To have your “covered documents” reviewed by the CBIC for completeness, bidders must submit those documents through the Connexion platform by the covered document review date deadline of Aug. 19. A covered document “means a financial, tax, or other document required to be submitted by a bidder as part of an original bid submission under a competitive acquisition program to meet the required financial standards.” For Round 2021 of the CBP, these are the tax return extract, income statement, balance sheet, statement of cash flow, and credit report with numerical credit score or rating.
With so many details that you need to cover, it might be easy to forget to upload one or more required financial documents into the Connexion platform. But just as even the best laid plans can fall apart due to one missing piece, so can your bid if you fail to submit all of the required financial documents that the CMS requires. The covered document review process will provide you peace of mind, knowing that your financial document submission is complete and properly submitted through the Connexion platform. Bidders should therefore make every effort to take advantage of this process.
Bidders who upload their covered financial documents in the Connexion platform before Aug. 19 are included in the Covered Document Review Process (CDRP). During this process, CMS will determine if any of your required financial documents are missing and will alert you within 90 days so that you may upload them. After the bid window closes on Sept. 18, only the covered documents identified and requested in a written notification from the CBIC as a result of the covered document review date (CDRD) process will be considered. Therefore, the Covered Document Review Process is a great opportunity for you to keep your Round 2021 bid on track. While the CDRP does not determine if your required financial documents are accurate, acceptable, complete, or in accordance with RFB instructions, many suppliers will find it quite useful to ensuring they submit every required piece of information.
We urge every supplier who plans to bid to submit all of their required documents early so that they can take advantage of this opportunity.

For more information, visit the CBIC website or the industry's education website.
Cara Bachenheimer leads the Government Affairs Practice at Brown & Fortunato and Kim Brummett is Vice President of Regulatory Affairs at the American Association for Homecare.