Accreditation is a review process that allows health care organizations to demonstrate their ability to meet the regulatory requirements established by a recognized accreditation organization (AO). Since the Centers for Medicare & Medicaid Services (CMS) mandated durable medical equipment, prosthetics orthotics and supplies (DMEPOS) accreditation, there have certainly been changes. The CMS Quality Standards have had minor modifications over the years, which haven’t changed what CMS wants their approved AOs to review during an accreditation survey. Each DME provider must be familiar with the CMS Quality and Supplier Standards, as these are the basis of most of the requirements mandated to participate in the DMEPOS program.
The public health emergency (PHE) brought about by COVID-19 did lead CMS to suspend the need for accreditation for three months for new and currently accredited providers—but this was short-lived. Now, with the suspension lifted, accreditation is required by CMS whether you are a new company coming into the market or a longstanding DMEPOS provider. A big challenge came about as other payers, including Medicaid, did not provide a suspension and continued to mandate that companies maintain accreditation or become accredited to be a new provider. It was a real challenge for AOs to do site visits when some states would not allow surveyors to travel into their state without an extended quarantine upon arrival.
The Rise of the Virtual Visit
CMS acknowledged the need for an ongoing process that would let companies receive or renew their accreditation, so it approved the use of virtual site visits to complete accreditation surveys. There are many different virtual site visit processes offered by AOs, so it is important to reach out to your accrediting organization to find a solution that best fits the needs of your business.
This will be even more important since the PHE could be extended until the end of 2021. When CMS approved virtual site visits, it included a two-step process, with a virtual site visit followed by an on-site, unannounced survey within six months of the end of the PHE or within one year of the virtual site visit, whichever occurred first. Because of the possible extension of the PHE through 2021, CMS is reevaluating the two-step process and the industry will soon receive additional clarification. If the PHE continues to be extended and CMS revises the timeline for the on-site survey, it is possible that your on-site survey would be followed very closely by your next accreditation cycle.
Most virtual site visits are very comprehensive and include a tour of the facility, interviews with personnel and a review of personnel and patient files. When setting up virtual site visits, the AO must ensure that the virtual platform is HIPAA complaint. In cases where a company chooses to use its own virtual platform for the virtual site visit, there must still be verification of HIPAA compliance.
Virtual Downsides
Virtual site visits do not work for every company. There can be internal complications that would prevent a company from participating in a virtual site visit. The most common complications include:
- The inability to scan information into a secure, designated computer so files can be reviewed; it is not enough to have a file held in front of the computer camera to review for accuracy
- The inability to use a tablet or smartphone containing the virtual platform to tour the facility, delivery vehicles and the warehouse to verify compliance with the CMS Quality Standards and Accreditation Standards
- Frequent internet outages in some areas and reduced speeds or quality of the streaming signal during the survey
- Surveying areas that are restricted due to the company’s COVID-19 response
- Observing actual patient setup and education; this can be very challenging as every company is limiting person-to-person contact during the pandemic
- Staff working remotely and not being available for an unannounced survey
The good news is that, because of the need to train companies on a virtual survey platform and the virtual site visit process, CMS does allow a 48-hour notice before the virtual site visit. This allows at least some time for preparation to help avoid the above issues.
It is possible that virtual visits in progress will need to be rescheduled due to internet interruptions. In most cases, site visits can be adjusted and in other cases, the AO must find a safe and efficient way to complete these surveys on-site. There is no doubt that on-site surveys are still a better way to verify the standards set forth by Medicare and the AO, but AOs have had to adjust the ways they do busines during the PHE.
Documentation Needs
DMEPOS providers have also had to adjust the way they do business. The biggest adjustment DMEPOS providers have made during the PHE is by making changes to their operations. Compiling a simple list of all the changes made is essential, because it documents the company’s adjustments to policies and practices, along with any newly implemented standards of practice. Companies often forget to write down the changes made to practices outlined in policies and procedures.
As accreditation organizations start their on-site survey process, they are going to want to ensure organization-wide compliance with changes that have been made and will need to be aware of the changes the organization has made. For example, many providers are implementing mask mandates for the delivery of equipment. Have your policies been updated to reflect this change? It is important to revisit the implemented changes at some point to determine whether they are still necessary or should become the new policies and procedures for your organization. Many providers do not realize how important policies are for their own protection.
Documentation of changes does not need to be a complicated process. Many things that providers have learned or practiced during the PHE are things that they were already doing in their daily operations; many will continue to keep many in practice once the PHE is lifted. A short list of items that may have been adjusted during this PHE include:
- Implementing curbside pickup of items
- Changing ways of cleaning and storing equipment
- Reducing personnel access to the office and warehouse
- Wearing personal protective equipment during each delivery
- Delivering to the doorstep instead of into the home
- Educating patients either by phone or in a virtual format
- Limiting patient access to your facility
- Requiring personnel to be quarantined after exposure to the virus
- Limiting or ceasing access to facilities that you service
- Limiting hours of operation
- Switching personnel working remotely and the added security needed to do so
- Training personnel on COVID-19
- Changing the types of medical necessity documentation obtained
The challenge for DME companies comes in finding creative ways to educate and service patients while running day-to-day operations in a safe, efficient manner. Let your AOs assist you with your processes, as accreditation should be embraced as a tool for your company’s success. Accreditation is not about finding what is wrong, but rather about ensuring that the company is meeting certain requirements and providing guidance on the best way meet those requirements when not being met.
Your AO can be a valuable partner in ensuring that you comply with all CMS and other regulatory requirements and can run your company in the way it supports the patients you serve. Choosing the right AO is the key to that success.
