From HIDA:

Alexandria, VA—The Health Industry Distributors Association (HIDA) submitted comments to the Internal Revenue Service (IRS) on the implementation of the medical device excise tax. Matthew Rowan, President and CEO of HIDA issued the following statement: 

“HIDA strongly recommends the IRS exempt kits, packs and trays from the medical device excise tax and requests IRS to define price as the price for the actual medical device after accounting for applicable discounts and rebates.”  HIDA also urges the IRS to “utilize a framework around the Food and Drug Administration’s “over-the-counter” or “home-use” criteria to exempt other products under the device tax retail exemption provisions.”

“Kitting” is a value-added service and precedent demonstrates it does not meet the definition of manufacturing.  HIDA’s comments describe “kitting” as the “act of taking individual medical products purchased from manufacturers and packaging them together for hospitals, surgery centers, physician offices, and home healthcare agencies.”  HIDA further states that “kits, packs and trays are used by providers to reduce healthcare costs, improve safety and improve patient care.”

“We appreciate the agency’s effort and willingness to understand the complex medical device supply chain prior to promulgating a proposed rule on implementing the medical device tax. We look forward to working with the agency throughout the device tax implementation process.”

HIDA’s comments can be viewed on the HIDA Web site.

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The Health Industry Distributors Association (HIDA) is the premier trade association representing medical products distributors. HIDA members primarily serve the nation’s hospital, long term care, and physician/alternate care markets. For more information, contact HIDA at (703) 549-4432 or visit

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