Providers who focus on the deadlines — and not the details — of the accreditation process can face an insurmountable level of deficiencies.
When HME companies try to complete the process in a short (often unrealistic) time frame, they encounter many problems. The longer a period of time you and your company team have to work on the process and conduct internal reviews and audits before your accreditation survey, the more successful your outcome should be.
For example, hurriedly gathering items required for personnel files can leave gaping holes. Surveyors often find that annual performance evaluations have not been completed, that orientation checklists are missing or incomplete, or that employees do not have documentation of Hepatitis B, either the vaccine or the declination. And there are many other required human resources items like these that can easily be overlooked when you're in a rush.
When an HME provider has adequate time to review the company's files with a checklist prior to being surveyed, the deficiencies can be noted, the corrections made and the needed documentation completed and filed. The day of the survey is not the time to find that your HR files are inadequate. But without taking the time necessary to review and audit, you might be facing lots of surprises on that day.
Common Survey Problems
One of the most common deficiencies found on HME providers' accreditation surveys occurs with patient record audits. For example, providers may get the referral for the patient and have a CMN or other billing document signed by the physician, but they do not have a complete order for the item.
This problem is particularly common with oxygen patients. The CMN provides a place to list the “maximum liter flow” the patient can receive, but this is not a complete order. Unless the provider hand-writes the complete order, or uses software that enters the information, into the blank area at the bottom of the CMN (such as “2 L/M via N/C continuous”), the provider must have a separate written order either on an order sheet, a prescription or other written means.
Having your accreditor's surveyor review charts the day of survey only to discover such a deficiency throughout your files is almost a guarantee that your company will have a poor outcome.
In the group of providers going through accreditation for the first time these past few months — in an attempt to meet CMS' Oct. 31 deadline to be considered for contracts in the first round of competitive bidding — there are many who will not be successful. They simply did not start early enough, could not get the work accomplished in time and will not be accredited before the deadline.
In addition, many of those who did achieve accreditation (regardless of the accreditation organization) had a tremendous amount of follow-up work to complete. CMS will validate these results when evaluating bids and awarding contracts only to those who were accredited in time.
Get Really Ready
Remember that accreditation generally takes from four to six months to accomplish.
Most accreditors also require a 60- to 90-day window of time to schedule an unannounced on-site visit. That means you should provide as much advance notice as you can that your company is ready. But you can't notify your accreditor that you are ready until you have completed your work and really are ready for the surveyor to walk through the door.
It's overwhelming to have to accomplish successful accreditation with both a bidding process underway and a deadline looming. Don't wait until a deadline is imposed in your service area by any of your payers, or for a deadline that could come at any time for all Medicare HME suppliers to be accredited.
Begin the process now so that you can proceed at a manageable pace, complete the work sufficiently and have a successful outcome without extraordinary follow-up. Don't get focused on the deadlines; focus on the detail that is needed.
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.
