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CMS-1503-FC 934<br />

We did not receive comments on the specific CBAs proposed <strong>for</strong> the New<br />

York-Northern New Jersey-Long Island, NY-NJ-PA MSA. However, we have decided<br />

to make three changes based on further consideration of issues raised by the PAOC. We<br />

carefully considered the PAOC suggestion noted in the proposed rule to exclude Pike and<br />

Putnam counties from the New York-Northern New Jersey-Long Island, NY-NJ-PA<br />

MSA in order to result in a smaller and more manageable CBA than the proposed<br />

North-West NY Metro CBA. This proposed North-West NY Metro CBA is a large area<br />

situated north and west of New York City and covering the three states of New York,<br />

New Jersey, and Pennsylvania. Pike County, Pennsylvania is a low population density<br />

area and makes up only 0.3 percent of the total DMEPOS utilization <strong>for</strong> the New York-<br />

Northern New Jersey-Long Island, NY-NJ-PA MSA. There<strong>for</strong>e, we believe that<br />

excluding Pike County from the North-West NY Metro CBA is consistent with existing<br />

regulations at §414.410(c). In addition, the PAOC pointed out that excluding Pike<br />

County, PA, would help reduce the burden of suppliers having to comply with different<br />

state licensure requirements. As noted in the proposed rule, the PAOC also suggested<br />

that CMS consider state licensure requirements when dividing the MSAs into CBAs. To<br />

eliminate the complexity of complying with different state licensure requirements, we<br />

have decided to split the proposed North-West NY Metro CBA into two CBAs: one<br />

containing the New Jersey counties of Bergen, Essex, Hudson, Morris, Passaic, and<br />

Sussex; and one containing the New York counties of Putnam, Rockland, and<br />

Westchester. To summarize, with regard to the proposed North-West NY Metro CBA,<br />

the PAOC suggested excluding Pike and Putnam counties to reduce the size of this large<br />

CBA we proposed <strong>for</strong> the area in the north and west of the MSA. It was noted by the

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