I'm sure you get the same emails I do each week from vendors offering ways to increase your sales by adding new products and product lines. But the question you need to ask is, “Will these products fit into the categories that I am accredited to provide?”
When CMS started the mandatory accreditation process a few years ago, the agency took what had been the industry accreditation procedure and turned it around a bit. Prior to the 2006 CMS Final Quality Standards when accreditation was voluntary, a DMEPOS provider became accredited for services. Now CMS requires that the accreditor provide a list of every item a provider is accredited to provide.
Here's how the items are categorized:
- Mobility Assistive Equipment
- Respiratory Equipment
- Durable Medial Equipment
- Orthoses
- Prosthetic Devices
- Enteral and Parenteral Nutrition
- Home Dialysis Equipment and Supplies
- Supplies
The idea behind accreditation by category is that an HME company could not get accredited for only one category and then begin to provide items from another. This makes sense for the situation that might occur when a company becomes accredited to provide the items listed under “durable medical equipment” and then suddenly decides to provide items from the “respiratory equipment” category. These two services require different considerations, such as administrative processes, staff competency and levels of expertise and, in some cases, additional state licensure.
When that email comes into your inbox, or that cheerful salesperson comes into your office, you may be tempted to jump on the bandwagon and take on new products. But remember to ask yourself, “Am I already accredited to do this?” If you are accredited in the “durable medical equipment” category, then you most certainly could add any of the items listed within the category. But if the item you are considering falls under another category, it may not be a simple addition.
Let's take, for example, therapeutic shoes. There is a growing interest in the opportunities and reimbursement potential available for these items. But not so fast.
Therapeutic shoes are classified as “custom fitted orthotics” and fall under Appendix C in the CMS Final Quality Standards. A provider must meet all of the accompanying requirements (including fitting and adjustment capabilities) as well as being accredited for orthotics. In other words, if you need to be accredited for an additional category, for therapeutic shoes or any new product, it will probably involve more work and expense.
In addition, note that Supplier Standard No. 25 states: All DMEPOS suppliers must disclose upon enrollment all products and services, including the addition of new product lines for which they are seeking accreditation. If a new product line is added after enrollment, the DMEPOS supplier will be responsible for notifying the accrediting body of the new product so that the DMEPOS supplier can be re-surveyed and accredited for these new products.
Logically, you should anticipate another unannounced onsite survey to ensure compliance with any new requirements.
In order to provide therapeutic shoes, there are also several states that require licensure and/or certification for fitters. Tennessee requires that personnel be a Certified Fitter of Therapeutic Shoes (CFts) credentialed by the American Board for Certification in Orthotics, Prosthetics & Pedorthics (ABC). Alabama state law requires any individual providing custom inserts to be a licensed pedorthist. Another five states require all therapeutic and/or diabetic shoe providers to be licensed pedorthists.
If you meet all of these requirements, then you should definitely consider adding these products for your customers. But if not, then you need to think about adding therapeutic shoes — or any new products or product lines. Start with ensuring that you are accredited to provide the products you are considering. If you are, great!
If you are not, be aware of the work and time required and then decide whether new additions are possible.
Read more Accreditation Now columns.
Mary Ellen Conway, RN, BSN, is president of Capital Healthcare Group, LLC, Bethesda, Md., which provides health care management expertise in accreditation preparation and survey follow-up, operations assistance, design of quality improvement programs and outcome measures. She can be contacted by phone at 301/896-0193 or through www.capitalhealthcaregroup.com.
