Many DME suppliers seem to think that once they become accredited, communication with their accreditor can move to the back burner for the next two to three years. But this could not be further from the truth. Your accreditor plays a very important role in ensuring that you are in good standing with Medicare every day over the course of your accreditation.
Remember that CMS dictates many processes that your accreditor must provide. As part of the Medicare Modernization Act of 2003, the accreditation requirement was meant to assist with ensuring that suppliers meet quality goals beyond the Supplier Standards. It was obvious that the National Supplier Clearinghouse, the contractor responsible for ensuring that the Supplier Standards are met, had not done its job. We've all seen the massive amounts of fraud committed by fictitious providers, those with empty offices and those in collusion with criminals. We are all paying the price for these bad apples.
CMS uses its approved DMEPOS accreditors as its eyes and ears in the field and makes many demands on them. You need to communicate with your accreditor proactively, as you would with any regulating authority. For example, you must let your accreditor know right away of any changes in your operation, such as a change of or addition to your location(s) on file, the addition of a product line, the addition or removal of a business partner, a change in your mailing address and more.
You know that you need to complete the 855-S form with these updates, but your accreditor must be aware of them as well so the information they have on file and the information they are required to communicate to CMS matches the information you submit on the 855-S. When you add new products or open a new location, you may be subject to an additional onsite survey, and you must have a new location accredited before you can receive a new supplier number.
Did you know there are red flags that CMS has identified as potential concerns for fraud? After looking at the companies found guilty of fraud, CMS has identified some items from among the common attributes of these bad apples that the agency believes could indicate a provider is fraudulent.
We know that one of these items is a dramatic increase is billing. Often this might come from the start of billing for new products or when opening a new location. These are legitimate processes that can be performed by legitimate providers, but they are common with fraudulent providers as well. If CMS finds a tremendous increase in your billing, the agency might contact your accreditor to make an unannounced visit to see what's happening.
Email addresses are another item CMS has identified as a possible indicator that a provider is not legitimate. If you use a free email provider such as Yahoo, Gmail or Hotmail, etc., you might want to change and use an email address from a purchased Internet service. CMS will notify an accreditor to investigate any providers who use these free services for their email address, so why risk it?
There are also various regions of the country where fraud has occurred that CMS is keeping an eye on. We know they exist, but CMS has not published a list of these “hot” zip codes. They have, however, identified these to the accrediting organizations, which are also required to keep an eye on locations in these areas.
Of course the most common concern that everyone is aware of is complaints. You are required to provide contact information for your accreditor to your customers as well as CMS. Your customers have a right to call CMS and/or your accreditor to make a complaint. Hopefully, this is only after they feel they have not received resolution from you. But either way, make sure you document all complaints — and document your attempts to resolve the complaint.
Your accreditor may be contacted by CMS to investigate some complaints. If the accreditor's representative comes to your site, he will ask to see your complaint log and will expect to see documentation of all of the complaints you have received.
Don't wait for your accreditor to show up or to contact you about problems. You risk having your supplier number revoked if you do not follow your requirements.
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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.
