ALEXANDRIA, Va.--In a letter to CMS Administrator Mark McClellan, the American Association for Homecare called the agency's proposed quality standards for suppliers "overly prescriptive" and urged the release of more details on accreditation.

The 24-page letter outlines the organization's concerns and recommendations for the draft standards, which were released Sept. 23 by CMS and its contractor Abt Associates, Cambridge, Mass. Expected to be finalized next year, the quality standards will be required of providers in the 10 cities where Medicare competitive bidding will begin in 2007--and eventually, of all DMEPOS suppliers who want to do business with Medicare (see HomeCare Monday, Sept. 26).

CMS' draft document focuses on two areas: business standards and product-specific requirements for items from oxygen and power wheelchairs to commodes and canes.

These details go too far, AAHomecare said, recommending that CMS eliminate detailed product standards for specific items and noting that some standards duplicate those already required by federal, state and local law. "CMS may have misunderstood the discussion by the [Program Advisory and Oversight Committee] about the need for product-specific standards. Certain lines of service such as respiratory, rehab and assistive technology, or infusion require specific standards to meet the needs of patients. This does not mean that every item of DMEPOS requires its own special set of standards."

Furthermore, the standards leave little room for the provider to exercise judgment when offering service, the association said. "Standards should establish the benchmark that a provider must meet, but should not be so specific that they dictate care or service."

In current form, the association continued, the standards are more like a checklist or operating manual, which "dilutes the value of accreditation."

AAHomecare also urged CMS to reveal more details about how it intends to implement mandatory accreditation. Agency officials have previously indicated that providers who are already accredited may have the opportunity to be grandfathered in, but have yet to issue specific details. The uncertainty has made many providers hesitant to begin the accreditation process, according to the association. "A clear policy statement from CMS on this issue favors all stakeholders and will encourage providers to seek accreditation now, promoting a smooth transition when all the standards are final," the letter stated.

Other suggestions by AAHomecare include:
--clarifying the role of the National Supplier Clearinghouse so providers are not subject to conflicting interpretations of standards;
--developing definitions for some of the terms in the draft standards and using them consistently. For example, "licensed," "certified," "credentialed" and "qualified" are all used in the same document, but no definition is given to differentiate the terms;
--resolving inconsistencies with Medicare reimbursement, coverage and billing requirements;
--eliminating the requirement that providers operate 40 hours a week, as long as a provider maintains appropriate access for emergency or an urgent after-hours contact;
--eliminating the blanket prohibition on using mail order delivery for all medical equipment;
--modifying the requirement that a provider should respond within 60 minutes of a beneficiary service call;
--eliminating the requirement that providers maintain financial records that comply with general accepted accounting principles;
--eliminating the requirement that a provider notify CMS and its accreditation organization when it first becomes aware of potential adverse financial operations;
--eliminating the requirement that providers establish a service plan for devices in Class I, which includes canes and walkers.

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Comments on CMS' proposed quality standards for suppliers are due Nov. 28. A draft of the standards is posted at www.cms.hhs.gov/suppliers/dmepos/compbid/default.asp. Submit comments to DMEPOS_Quality_Standards_Public_Comments@cms.hhs.gov.

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