Will You Be Prepared?

In September, CMS issued draft quality standards with which all durable medical equipment, prosthetics, orthotics and supplies (DMEPOS) suppliers will have to comply at some time in the not-so-distant future. Most would agree that universally applicable quality standards can serve a number of positive functions.

First, if properly implemented, they reduce the risk that a Medicare beneficiary will be victimized by an unscrupulous provider. Accrediting entities will act as a private validation of a provider's business processes, policies and actions. Second, the standards can serve as an important compilation of federal requirements for DMEPOS suppliers. Third, they create the opportunity for providers to improve their service to beneficiaries and the efficiency of their operations.

There are, however, significant concerns with the draft quality standards. First, preparing for accreditation is a very intensive and time-consuming process. Smaller suppliers will be disproportionately impacted because they are less likely to have the personnel to dedicate to the task. In many instances, the draft standards impose requirements that do not reflect the reality of small business operations or that may create particular hardship for small businesses.

Second, in many instances, the draft quality standards take an encyclopedic approach that will bind suppliers. Individually, many of these standards are not objectionable, but their separate delineation will require separate documentation during the accreditation process. Where possible, CMS should reduce the number of standards and make them more general.

CMS also will have to recognize that quality standards are likely to increase the standards with which all businesses will be required to comply if they wish to serve Medicare beneficiaries. The aggregate cost of all standards included in this proposal will significantly increase the cost of doing business with Medicare at a time when CMS is looking for ways to reduce its overall reimbursement rates for DME products. This must be taken into consideration as CMS compares its pricing schedule to other payers as it sets future fee schedules. With competitive bidding implementation looming closer and closer, suppliers will have to understand their total delivered costs in order to submit bids that are realistic.