Grandfathering for CBA

There is a common question that has come up recently about fulfilling the requirements for CMS, and about proof of delivery of grandfathering letters for competitive bidding. Right now CMS still does not have a formal requirement defined. Below is a comment from the CBIC liaison Renea Carter. “Yes, retaining a copy of the letter fulfills this requirement. CMS does not have any formal requirements for this record-keeping.  If your members have questions, they may contact your CBIC Liaison, Renea Carter at 718-221-4717 or renea.carter@palmettogba.com.   (http://www.palmettogba.com) The retention of the letter is similar to the requirements for the old rent/purchase option letter.” Provided is a fact sheet for Grandfathering Requirements for Non-Contract Suppliers.