Annual Education Requirements
As the New Year is beginning, it seems fit to review one of the annual requirements we have from our accreditors: Annual Education. The Centers for Medicare & Medicaid Services (CMS) Final Quality Standards require education be provided to all DME “technical staff,” which includes any staff member who delivers or instructs items in person or troubleshoots equipment over the phone. Compliance with The Final Quality Standards is enforced by your accreditor, and in doing so your particular accreditor’s standard may list a yearly amount of hours (and sometimes the topics) of education that suppliers must provide to their DME staff who instruct patients.
The Annual Education standard is commonly found deficient on re-surveys, especially for small suppliers, as they often “forget” to create their calendar, and even if they do create it suppliers may not implement the schedule as planned. Meeting this standard can be less complex for a large supplier who has an electronic system that tracks and manages employee compliance. Some small- to medium-size providers offer that compliance with this standard is challenging. But requirements such as these do not have to be cumbersome. Compliance can be very routine and reasonable. If this has been a challenge for you, why not adopt some best practices implemented by successful small suppliers?
Start by making sure that you have a standard sign-in sheet that you use to document staff attendance/participation in each educational program that can be filled in a binder labeled “Annual Education.” The sign-in sheet can be a standard form that is completed by hand at each session. It needs to have blank lines where information such as the date, topic and speaker/item used can be completed, as well as enough room/lines for each attending staff member to sign. File the completed sheets for each program in this binder with any materials/handouts provided at the session, or at a minimum a short description of what the program was. Place a copy of the 2013 calendar you create as page one of the binder along with the original sign-in sheet and blank copies in the interior left-pocket in the front so that you house everything in one place. Add 2014, 2015 and subsequent years on top each year so that when your surveyor comes onsite for re-survey you can simply hand them the complete binder rather than struggling to gather information and be able to show immediately that you have met your requirement. As new accreditation cycles begin, start a new binder.
In terms of the schedule start by sitting down now, in January, and creating your plan for the entire year. Start your schedule with February and plan for at least 6 to 8 one-hour programs for the year, being sure to schedule at least the minimum sessions required by your accreditor (if you have a minimum number of hours required). Don’t schedule programs during your busiest months, which may be November/December or might be a spring or summer month when you are short-staffed due to vacations.
For the 2013 calendar year, schedule a day and time during these months for a “Munch and Learn.” Pick a consistent time—early morning, during lunch, late afternoon—or more than one time during a single day, whatever works best with your staff and their availability. You can certainly provide light snacks, food and/or drinks, but you don’t have to. You can tell the staff to brown bag their lunch or snack that day and bring it with them. Select a day mid-month on a Tuesday, Wednesday or Thursday so that you are not scheduling a program on your busy Mondays and Fridays at the beginning and end of the month.
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