The View from 30,000 Feet

It's time to take a 30,000-foot view of what has happened with mandatory accreditation for DMEPOS suppliers. Where are we? What have we learned and where are we headed? Let's go back a bit to review, and look ahead at what's coming next.

Accreditation History 101

In December of 2003, the Medicare Modernization Act was signed into law. This legislation required accreditation for any Part B supplier who planned to bill Medicare, whether they were a participating or non-participating supplier. The mandate included all Part B suppliers providing DMEPOS, such as pharmacies providing diabetic supplies, physicians providing "bent metal," physical therapists providing rehab equipment, orthotists, pedorthists and more.

The Centers for Medicare and Medicaid Services realized the need for a process that could ensure suppliers were meeting quality standards and to provide onsite visits. The agency turned to accreditation.

Additionally, the MMA established a competitive bidding program for DMEPOS and required that all suppliers who wished to bid must be accredited. Since there was a wide disparity of requirements among existing accrediting organizations, CMS developed its own quality standards and said it would name approved, or "deemed status" accreditors that would adopt these standards.

The agency also changed the way accreditation for DMEPOS (previously voluntary) was conducted, requiring that its accreditors provide the "items" each supplier was accredited to provide.
Today (and since 2008), if a supplier submits a claim for an item that does not match the list of accredited items provided by their accrediting organization, the claim is denied.

In 2005, CMS issued its "Draft Quality Standards," a 104-page document that was judged by many to be over-the-top in proposed requirements, among them having a certified wound-ostomy nurse involved in the setup of every support surface and requiring a face-to-face meeting with all mail-order recipients. CMS received over 5,600 comments on the draft from the HME community.

After digesting these comments, CMS issued its much simplified 14-page "Final Quality Standards" on Aug. 14, 2006, and announced the deemed status accreditors on Nov. 16, 2006.

It wasn't until 2007, however, that CMS announced the Oct. 1, 2009, mandatory — or "drop dead" — accreditation deadline for HME companies. The agency also announced that all suppliers who planned to bid in Round 1 of competitive bidding would need to be accredited by Sept. 1, 2007.