I'm sure you get the same emails I do each week from vendors
offering ways to increase your sales by adding new products and
product lines. But the question you need to ask is, “Will
these products fit into the categories that I am accredited to
provide?”
When CMS started the mandatory accreditation process a few years
ago, the agency took what had been the industry accreditation
procedure and turned it around a bit. Prior to the 2006 CMS Final
Quality Standards when accreditation was voluntary, a DMEPOS
provider became accredited for services. Now CMS requires that the
accreditor provide a list of every item a provider is accredited to
provide.
Here's how the items are categorized:
- Mobility Assistive Equipment
- Respiratory Equipment
- Durable Medial Equipment
- Orthoses
- Prosthetic Devices
- Enteral and Parenteral Nutrition
- Home Dialysis Equipment and Supplies
- Supplies
The idea behind accreditation by category is that an HME company
could not get accredited for only one category and then begin to
provide items from another. This makes sense for the situation that
might occur when a company becomes accredited to provide the items
listed under “durable medical equipment” and then
suddenly decides to provide items from the “respiratory
equipment” category. These two services require different
considerations, such as administrative processes, staff competency
and levels of expertise and, in some cases, additional state
licensure.
When that email comes into your inbox, or that cheerful
salesperson comes into your office, you may be tempted to jump on
the bandwagon and take on new products. But remember to ask
yourself, “Am I already accredited to do this?” If you
are accredited in the “durable medical equipment”
category, then you most certainly could add any of the items listed
within the category. But if the item you are considering falls
under another category, it may not be a simple addition.
Let's take, for example, therapeutic shoes. There is a growing
interest in the opportunities and reimbursement potential available
for these items. But not so fast.
Therapeutic shoes are classified as “custom fitted
orthotics” and fall under Appendix C in the CMS Final Quality
Standards. A provider must meet all of the accompanying
requirements (including fitting and adjustment capabilities) as
well as being accredited for orthotics. In other words, if you need
to be accredited for an additional category, for therapeutic shoes
or any new product, it will probably involve more work and
expense.
In addition, note that Supplier Standard No. 25 states: All
DMEPOS suppliers must disclose upon enrollment all products and
services, including the addition of new product lines for which
they are seeking accreditation. If a new product line is added
after enrollment, the DMEPOS supplier will be responsible for
notifying the accrediting body of the new product so that the
DMEPOS supplier can be re-surveyed and accredited for these new
products.
Logically, you should anticipate another unannounced onsite
survey to ensure compliance with any new requirements.
In order to provide therapeutic shoes, there are also several
states that require licensure and/or certification for fitters.
Tennessee requires that personnel be a Certified Fitter of
Therapeutic Shoes (CFts) credentialed by the American Board for
Certification in Orthotics, Prosthetics & Pedorthics (ABC).
Alabama state law requires any individual providing custom inserts
to be a licensed pedorthist. Another five states require all
therapeutic and/or diabetic shoe providers to be licensed
pedorthists.
If you meet all of these requirements, then you should
definitely consider adding these products for your customers. But
if not, then you need to think about adding therapeutic shoes
— or any new products or product lines. Start with ensuring
that you are accredited to provide the products you are
considering. If you are, great!
If you are not, be aware of the work and time required and then
decide whether new additions are possible.
Read more Accreditation Now
columns.
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.
