Many DME suppliers seem to think that once they become
accredited, communication with their accreditor can move to the
back burner for the next two to three years. But this could not be
further from the truth. Your accreditor plays a very important role
in ensuring that you are in good standing with Medicare every day
over the course of your accreditation.
Remember that CMS dictates many processes that your accreditor
must provide. As part of the Medicare Modernization Act of 2003,
the accreditation requirement was meant to assist with ensuring
that suppliers meet quality goals beyond the Supplier Standards. It
was obvious that the National Supplier Clearinghouse, the
contractor responsible for ensuring that the Supplier Standards are
met, had not done its job. We've all seen the massive amounts of
fraud committed by fictitious providers, those with empty offices
and those in collusion with criminals. We are all paying the price
for these bad apples.
CMS uses its approved DMEPOS accreditors as its eyes and ears in
the field and makes many demands on them. You need to communicate
with your accreditor proactively, as you would with any regulating
authority. For example, you must let your accreditor know right
away of any changes in your operation, such as a change of or
addition to your location(s) on file, the addition of a product
line, the addition or removal of a business partner, a change in
your mailing address and more.
You know that you need to complete the 855-S form with these
updates, but your accreditor must be aware of them as well so the
information they have on file and the information they are required
to communicate to CMS matches the information you submit on the
855-S. When you add new products or open a new location, you may be
subject to an additional onsite survey, and you must have a new
location accredited before you can receive a new supplier
number.
Did you know there are red flags that CMS has identified as
potential concerns for fraud? After looking at the companies found
guilty of fraud, CMS has identified some items from among the
common attributes of these bad apples that the agency believes
could indicate a provider is fraudulent.
We know that one of these items is a dramatic increase is
billing. Often this might come from the start of billing for new
products or when opening a new location. These are legitimate
processes that can be performed by legitimate providers, but they
are common with fraudulent providers as well. If CMS finds a
tremendous increase in your billing, the agency might contact your
accreditor to make an unannounced visit to see what's
happening.
Email addresses are another item CMS has identified as a
possible indicator that a provider is not legitimate. If you use a
free email provider such as Yahoo, Gmail or Hotmail, etc., you
might want to change and use an email address from a purchased
Internet service. CMS will notify an accreditor to investigate any
providers who use these free services for their email address, so
why risk it?
There are also various regions of the country where fraud has
occurred that CMS is keeping an eye on. We know they exist, but CMS
has not published a list of these “hot” zip codes. They
have, however, identified these to the accrediting organizations,
which are also required to keep an eye on locations in these
areas.
Of course the most common concern that everyone is aware of is
complaints. You are required to provide contact information for
your accreditor to your customers as well as CMS. Your customers
have a right to call CMS and/or your accreditor to make a
complaint. Hopefully, this is only after they feel they have not
received resolution from you. But either way, make sure you
document all complaints — and document your attempts to
resolve the complaint.
Your accreditor may be contacted by CMS to investigate some
complaints. If the accreditor's representative comes to your site,
he will ask to see your complaint log and will expect to see
documentation of all of the complaints you have received.
Don't wait for your accreditor to show up or to contact you
about problems. You risk having your supplier number revoked if you
do not follow your requirements.
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.
