All of the accreditation deadlines for the DMEPOS community will now occur within the next year. But it's been hard to keep up with the announcements from CMS, and often the deadline information has been confusing. It's time to review all things accreditation from A to Z.
A is not just for accreditation but for accomplishment. Accreditation is a badge of honor that you can display proudly to your customers and referral sources, even though CMS has now made it a requirement. There will be providers who do not become accredited and who will not be in business in the coming years.
This is an accomplishment you should advertise and include in all of your communications with the public.
B is for being accredited before you obtain a new Medicare supplier number from the National Supplier Clearinghouse.
Since March 1, in order to get a new supplier number, a supplier with fewer than 25 locations must first be accredited. This can present a challenge for those opening a new business.
It is also a consideration for those existing businesses that are not yet accredited (with under 25 locations) that are acquiring or opening a new location. Once a supplier is accredited, the accreditation is extended to a new location, but in the meantime, the supplier must go through the accreditation process before obtaining its supplier number.
C is obviously for CMS, the Centers for Medicare and Medicaid Services. But CMS is not your only payer. Even though CMS is requiring suppliers to become accredited, there are many other payers that are and will be requiring accreditation as well, including managed care organizations and several state Medicaid programs.
CMS has published the Final Quality Standards (although revisions are due out any time) that companies must review and become comfortable with. The standards can be found at: www.cms.hhs.gov/MedicareProviderSupEnroll/Downloads/DMEPOSAccreditationStandards.pdf.
D is for critical deadlines: today, Jan. 31, 2009, and Sept. 30, 2009, and we'll get to those later. “D” is also for documentation. In this business, if it wasn't documented, it wasn't done. Ensure that you and your staff document everything, and make certain you also have documentation verifying all of the items received by the customer (see the sample “Verification of Receipt of Paperwork” on page 118).
E is for exemptions. CMS has NOT exempted routine suppliers, and the Sept. 30, 2009, deadline for HME providers, pharmacists and pharmacies still stands.
But section 154(b) of the Medicare Improvements for Patients and Providers Act added a new subparagraph to the original legislation. Unless CMS releases standards that are more specific to this group, or re-evaluates the current standards, the following eligible professionals are now exempt from meeting the deadline:
- Physicians (as defined in section 1869(r) of MIPPA)
- Occupational therapists
- Physical therapists
- Qualified speech-language pathologists
- Physician assistants
- Nurse practitioners
- Clinical nurse specialists
- Certified registered nurse anesthetists
- Certified nurse-midwives
- Clinical social workers
- Clinical psychologists
- Registered dieticians
- Nutritional professional
- Orthotists
- Prosthetists
- Pedorthists
- Opticians
- Audiologists
F is for Form 855S. Existing DMEPOS suppliers (with the exception of those mentioned in “E”) enrolled in the Medicare program are required to submit proof of their accreditation via an updated Form 855S to the NSC by Sept. 30, 2009. We are told that the NSC will revoke the billing privileges of those (participating and non-participating) who do not submit the accreditation information by this date on Oct. 1, 2009.
G is for getting started. None of the accreditors will tell you that you need to hire a consultant to get started, because you don't. All of the accreditation programs are designed to be completed on your own.
But if you don't know where to begin, don't have enough staff to accomplish what you need or generally need help getting organized or creating a workable timeline, you might want to hire some help for the short term.
Interview your consultant, and look for one who has offered accreditation assistance over many years, not someone who saw an opportunity and leapt into this field with no history with accreditation outside of their own business. Most qualified consultants charge between $900 and $2,000 per day plus travel expenses.
H is for hospice. One more accreditation deadline to acknowledge is the requirement that Medicare-certified hospice providers must contract with only accredited DMEPOS suppliers as of Dec. 2, 2008. CMS has clarified this requirement to explain that if the supplier is not yet accredited, the supplier must be in the process of accreditation by this date.
I is for infection control and safety. Your accreditor has standards that require you to document and adhere to your policies regarding the manner in which your DME items are decontaminated and cleaned, serviced and repaired, stored and delivered.
Safety issues include OSHA, safety equipment and training, emergency preparedness and more.
Your accreditor may require that you report infections of patients or staff. Your staff will be observed using the personal protective equipment during equipment servicing and cleaning and in visits or contact with patients, including their hand-washing.
Your accreditor's standards will provide the guidance you need to ensure that you are complying with proper infection control practices and have implemented adequate safety measures.
J is for Jan. 31, 2009. This is the most recent deadline announced that coincides with the September 2009 accreditation deadline.
CMS has finally acknowledged publicly that it may take up to nine months to complete the accreditation process, and the agency says this new deadline is the date by which suppliers not yet accredited must submit a completed application to their chosen accrediting organization.
This January deadline is expected to ensure that providers will be able to complete their accreditation requirements before the Sept. 30, 2009, deadline as long as they are enrolled by this date.
K is for the key to keeping your human resource files complete. Incomplete HR files are one of the main reasons HME companies have difficulty on survey. Such items as keeping up-to-date licenses in the files, having annual performance evaluations, complete background or reference checks (as applicable), accurate job descriptions and more can cause problems.
Managing your HR files can be a headache, but knowing your accreditor's requirements and creating a tickler system to keep you organized and on track is the key to your success.
L is for lack. Generally, there are several common reasons that HME companies fail survey. These include:
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Lack of preparedness and few staff aware of process/requirements;
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Lack of focus and follow-through, not completing all pre-survey activities; and
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Lack of complete patient medical records, including missing Physician Orders and lack of documentation verifying the patient received all of the required information.
M is for MIPPA, the Medicare Improvements for Patients and Providers Act. This is the bill, passed in July, that delayed the implementation of competitive bidding, among other provisions.
N is for the necessary items needed for successful accreditation. One of the single-most important items is a complete policy and procedure manual. Your manual must meet the needs and requirements of the both the accreditation provider you select as well as the CMS Final Quality Standards.
The cost for a manual can range anywhere from $500 to $4,000. Some sell by component and still others sell with associated “free” consulting. Review what you are purchasing and make sure it meets your needs.
At this point, it is certainly not worth your time trying to create a manual on your own, but any manual should be able to be customized to describe your organization and your processes. It should contain crosswalks to show how the policies relate to your accreditor's standards as well as the CMS Final Quality Standards and provide you with audit tools, competency evaluations, job descriptions and more.
O is for organizations. CMS has approved 10 accrediting organizations whose standards and accreditation processes meet the agency's Final Quality Standards. The list of these organizations can be found at www.cms.hhs.gov/MedicareProviderSupEnroll/Downloads/DeemedAccreditationOrganizations.pdf.
Do your homework as you select your accreditor, as not all 10 may be an option for you. Contact and interview the organizations you are interested in, and don't choose an accreditor based on fees alone. Understand their process and expectations, ask for a list of accredited providers you can call to see how the process was for them, then make your selection after careful research.
P is for Performance Improvement or Performance Management. The CMS Final Quality Standards require that you collect information on five indicators of performance (see the list on page 116). These are usually one of the first challenges for those who are new to accreditation, since this is generally one thing that businesses may not be used to doing. It does not have to be a complicated process but must be done to meet the standards.
Q is for quick. Move quickly, because you really don't have a lot of time left to start the accreditation process.
Contact the accreditors, speak with them at Medtrade at their booths and on the show floor in Accreditation Central. Make your selection, send for their standards and get going quickly.
R is for reasons. There are many reasons why the most savvy DME business-owners are completing the accreditation requirement well in advance of the deadlines and realizing that it is not prudent to wait any longer. Thinking there is plenty of time in the next year to accomplish this goal is foolish.
S is for Sept. 30, 2009, the “drop dead” date by which DMEPOS suppliers billing Medicare for Part B products and supplies must be accredited.
T is for today. The first and most immediate deadline for those who need a new Medicare supplier number from the NSC is: today! This is currently a huge challenge for suppliers who are trying to obtain or renew Medicaid numbers in some states, such as New York.
There are states that require a supplier to have an active Medicare supplier in order to get a Medicaid number. If the supplier did not renew its Medicare number, or maybe never had one to begin with, now the company cannot get a Medicaid provider number without it. And of course, the Catch 22 is that you can't have a new Medicare number if you are not accredited.
U is for unannounced. On-site accreditation surveys must be unannounced and are generally scheduled in a 45- to 90-day window.
If it takes your HME company six months to complete preparation work before notifying the accreditor you are ready, it could easily be another two months before the on-site survey occurs. If there are deficiencies to correct after the survey, this process can extend the time it takes for your company to become accredited.
V is for vacuum. You cannot adequately prepare for accreditation with only one staff member working in a vacuum. Accreditation extends throughout your entire organization, and you need to involve as many staff members as possible.
W is for the work involved in your accreditation preparation activities. The work can be very difficult or be very manageable if you dedicate specific time and resources to the project, support the staff working on the accreditation preparation and, if possible, divide the work into manageable components.
X is for eXtra things to review and make sure you keep in mind. There are different processes by which surveyors or their organization require your on-site survey to be conducted.
No matter how your survey is conducted, however, note that the surveyor also will likely ask to review such items as your on-call logs (make sure they are complete); the contracts you have with providers, such as staffing companies or those that provide services or equipment for your company; as well as your marketing materials and advertisements to ensure that you are marketing only for those products you actually provide.
Y is for whY are we doing this? The reason is because of the millions and millions of Medicare dollars that have been paid to fraudulent providers.
These few bad apples have made it clear there needs to be accountability in this industry by compliant providers. At present, there are only 22 states with some form of DME licensure in place, so there would be no way to enact similar licensure requirements through all of the state legislatures to create a level “quality” playing field.
Accreditation is the logical solution to answering this need. The industry applauds quality requirements that hold a standard for all to adhere to and the means to enforce a level quality playing field is through the accreditation requirement.
Z is for zero, zip and zilch. That is what you will be getting reimbursed if you do not become accredited.
This A to Z listing is meant as a guide to many of the issues you need to take into consideration. Take advantage of Medtrade, your state associations and conversations with your peers to get more information as you make the selection of your accreditation organization.
I'll repeat that it is time to make your choice, send for the standards and get rolling. Time is up, and CMS has stated the agency has no plans for extending any of the deadlines that have been announced.
If you need help, whether it is because you've waited too long or because you don't have enough staff, then get it.
Plan to be ready for your on-site survey before next summer, when the last deluge of providers who have waited until the last minute to begin are getting accredited.
If you delay accreditation any longer, you risk losing your supplier number, not to mention your Medicare customers first, followed by your customers with managed care or Medicaid programs that require accreditation as well.
Bite the bullet, get it done! No more excuses or delays.
Performance Improvement Requirements
The CMS Final Quality Standards require that providers implement a performance management plan that measures outcomes of customer service, billing practices and adverse events and at a minimum, measures:
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Beneficiary satisfaction and complaints
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Timeliness of response to questions, problems and concerns
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Impact of business practices on adequacy of beneficiary access to items, services and information
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Frequency of billing/coding errors
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Adverse events
Verification of Receipt of Paperwork
Make sure that each of your new customers receives adequate paperwork when you begin service. To prove customers have received this information, always use a checklist that they sign and you keep on file.
Sample Verification of Receipt of Paperwork
Customer Name:__________________________ Date: _________
Item(s) received:________________________________________
I have received as my copies the following information:
Welcome to ABC DME
Company Information/Hours of Operation
Customer Rights and Responsibilities
Our Complaint Procedure
Information on Emergency Preparedness
Home Safety Information
Copy of CMS 21 Supplier Standards
HIPAA Information
Educational and Instruction Materials for the DME received
Assignment of Benefits and Your Financial Responsibility
Medicare Authorization and Your Fees
Consent for Third Party Review
Additional Items if needed:
• ABN
• Other: ____________________________________________
Customer Signature:_______________________ Date: _________
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.
