Not surprisingly, Medicare has issued new deadlines for accreditation with regard to competitive bidding.
First, here are the dates that have not changed. The “drop dead” date by which all providers must be accredited is still Sept. 30, 2009. There is no change to this requirement. CMS tells us that as of Oct. 1, 2009, in order to bill assigned or unassigned claims for the more than 400 items that have been identified, DME providers must be accredited by one of the 10 approved Medicare accrediting organizations or their claims will be denied.
As of press time, we still don't know the zip codes that are within each MSA in round two, so that makes it difficult for providers in outlying areas to know if they will need to bid or not. Originally, providers planning to bid in round two were required to apply for accreditation by May 14, 2008. That date has now been extended to July 21.
Hopefully CMS will release the zip codes for the next 70 MSAs before that date so that providers will know whether they serve beneficiaries in those areas. Right now, many providers are registering to bid only on a hunch as to whether the population they serve that live outside of the 70 urban areas identified will be included.
Remember, signing up is different with each accreditor. Some require that you actually complete an application, while others require that your application be submitted when you are ready to be surveyed. Check with your accreditor to make sure you are following their requirements. The accreditor, in turn, reports to CMS that you are registered for accreditation, and that's how CMS ensures you meet the requirement.
The second change is that providers need to be accredited by Jan. 14, 2009, in order to bid in round two. Originally, this date was Oct. 31, 2008, but again, without knowing all of the zip codes that define the round two bid areas, providers are unsure whether or not they will be bidding. The good news is this extension gives providers more time to do a good job on accreditation preparation.
Keep in mind, however, that the 10 accrediting bodies are not going to wait to conduct a provider's first survey in the last 30 days of the accrediting period, which would include the Christmas, Hanukkah and New Year's holidays. So, you should plan to have your survey completed by mid-December. That means since providers must have unannounced surveys, and accreditation organizations schedule these over a 60- to 90-day period, you should be ready for survey in September/October.
As always, make sure you look around and observe what's happening. Recently I was at a small pharmacy provider in rural Pennsylvania who is ready for his unannounced survey. He has no payer deadlines to meet for accreditation other than Sept. 30, 2009, and only needs accreditation to provide glucometer strips and lancets, nothing more.
The pharmacy provider was playing golf with a pharmaceutical representative recently who told him, “I don't know why you're going through all of this. You know you don't have to be accredited if you're not going to bid.” But the sales rep is wrong.
Although there are some minor exceptions, the accreditation requirement applies to every provider, including DME providers, pharmacies supplying DME, physicians, occupational and physical therapists who provide DME, nursing homes providing enteral products — EVERYONE! NO ONE IS EXCLUDED! Many providers are confusing competitive bidding with the accreditation requirement; make sure you are not one of them.
If you never have anything to do with competitive bidding — even if the program gets delayed or goes away altogether — you still must be accredited in order to bill Medicare for those identified items after Sept. 30, 2009. Why wait for any other deadlines? Get moving and work through the process at your own pace rather than hurrying through a forced timeline.
For now, get out your eraser and change those dates in your calendar. And while you're at it, select your accreditor and get going!
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.
