Providers in the first 10 metropolitan statistical areas selected for competitive bidding — who have been struggling to become accredited as well as to bid — have been overwhelmed with all they've had to do in the last few months. CMS' short time lines for this round certainly didn't help.
By now, everyone is well aware that CMS is requiring DMEPOS providers who wish to win Medicare contracts be accredited by one of 10 approved accrediting organizations by Oct. 31. The agency released its final supplier quality standards in August of last year. The 14 pages of standards are relatively straightforward, and the “deemed” accrediting organizations have created specific standards for compliance with CMS' final standards in addition to others.
But there is a wide range of requirements among the 10 accreditors. Providers may find everything from a few additional standards to comply with to dozens of additional requirements to maintain. So, it is important to make an informed decision when selecting your accreditation provider.
If you are not already accredited, it would also be wise to get prepared. The next 70 MSAs are expected to be announced this year for the second round of bidding, and, at some point, all providers will have to become accredited in order to bill Medicare for identified products.
Rumor is that the “drop-dead” date for accreditation may be as early as April of 2009.
Many providers in rural or small metropolitan areas may think they have plenty of time before an accreditation deadline is imposed on them, but it is shortsighted to wait for an announcement from CMS alone. It is important to remember that CMS is not your only payer. Many of your peers have experienced surprise deadlines from several third-party payers.
Last year, for example, Anthem Blue Cross sent notices to DME providers in New England that they would have to become accredited. And this summer, the Oklahoma Medicaid program sent all providers a letter informing them that, in order to participate in the Sooner Care Program, they would need to be accredited by one of the 10 CMS-approved accrediting organizations. Even though you may not have a CMS deadline approaching this year, you could be caught off guard by other payers with whom you participate that may suddenly announce an accreditation deadline.
Accreditation generally takes at least four to six months to accomplish. You should also consider the time it takes for your accreditor to make an unannounced site survey of your company. Many of CMS' accreditors require a 60- to 90-day window to schedule an on-site survey.
Your accreditor may also require a three- to four-month “track record,” meaning that you must have implemented forms and processes for at least that period of time before notifying the accreditor that you are ready for the survey. If your company needs a policy and procedure manual, competency program or updated educational materials, it may require even more time to get these pieces in place as you work through your accreditor's standards.
Providers that do not have time to prepare adequately for a survey may ultimately not pass successfully on their first try. At worst, unprepared companies may fail. At best, they will have one or more additional unannounced site visits from a surveyor to ensure that all requirements are being met.
Often, providers that need additional surveys will have to submit written materials (plans of correction) to document that the necessary changes have been made and that processes are in place.
When providers are rushing to meet accreditation deadlines, the pressure is on, particularly if the payers involved have issued short time lines. Providers who have struggled through these deadlines will tell you, “Don't wait!” Pick an approved organization, send for their standards and GET GOING!
Don't wait for someone to tell you that you have to be finished in the next few months. Work through the accreditation process, do it right the first time, and get through your survey without any additional follow-up visits.
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.
