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.
