Unless you've been living under a rock for the past few years,
you are no doubt aware that the Medicare Modernization Act of 2003
requires that medical equipment providers who bill Medicare for
identified Part B products and supplies will have to become
accredited. Accreditation programs for DME have been around for
more than a decade, but your company's first attempt at
accreditation may prove no small task.
Background
When the industry learned that accreditation would be mandatory,
we also learned that accreditation organizations would be the
bodies assigned to enforce and manage compliance. CMS is not
contracting with state health departments to ensure compliance with
this group of standards, as is their practice in home health and
hospice.
In September 2005, CMS released 104 pages of draft quality
standards with an over-the-top addition of many extreme, and
sometimes ridiculous, expectations. It looked as though the
contractor CMS used gathered everything every home care provider
might be required to do to comply with any regulatory or
accreditation requirements, and then turned these tasks into CMS'
quality standards. At the time, there was an outcry from the
industry, and a sea of comments were submitted.
So in August 2006 — after 5,600 comments had been received
on the draft standards — CMS released its final quality
standards. These standards, which ended up at only 14 pages, are
straightforward and very much reduced from the requirements that
had been included in the draft proposal.
Next, all accrediting organizations that wished to be recognized
by CMS sent their programs in for review. Some of the programs had
existing standards that were more stringent or comprehensive than
others. But it subsequently became clear that, ultimately, CMS
didn't care what other standards the accreditors required in their
programs as long as they had standards that met the government's
final quality standards word-for-word.
CMS also required that the accreditors award accreditation to
providers who meet the agency's quality standards, regardless of
whether or not they pass any additional standards the accreditor
may have in place. It will be interesting to see how this is going
to work in the upcoming months.
Previously, accreditation for DME has been voluntary, and
providers have chosen the accrediting organization they wished to
use. Until this year, only some networks and managed care
organizations have required accreditation in different areas of the
country.
Also, surveys had always been scheduled with providers, but CMS
now requires that all surveys, even those for a corporate office,
must be unannounced. This is an easy process for an accrediting
organization but a challenge for corporate and network surveys,
where administrative staff may need to be present for a survey even
though they may not reside where the corporate office is
located.
Among other requirements CMS has imposed on its 10 approved
accrediting bodies, the agency also requires that these
organizations:
Prioritize surveys for those suppliers in the MSAs selected for
competitive bidding in 2007;
Prioritize surveys for those suppliers who need to bid in the
second round; and
Consider any previous accreditation, certification and/or
licensure findings that indicate that DMEPOS quality standards are
being met at the time the accreditation organization surveys the
supplier.
The Link with Competitive Bidding
At this time, there is no final date for when all providers must
be accredited, but for now, it is required that providers who wish
to participate in competitive bidding must be accredited.
Competitive bidding is scheduled to begin this year in 10 of the
country's largest metropolitan statistical areas — excluding
New York, Los Angeles and Chicago.
If you are in any of the potential MSAs that CMS has targeted,
your time has come. And when an additional 70 MSAs are brought on
for bidding in 2009, it's going to be crowded. The lesson is that
there's no time or good reason to wait any longer. The question is,
however, how do you decide which accrediting organization is right
for you?
Selecting Your Accreditor
The truth is, with most of CMS' “deemed”
accreditors, your accreditation generally lasts for three years. If
you are unhappy with your accreditor, then you can switch to
another before your next renewal.
There are a few items you should consider, however, when making
your selection.
- CMS is not your only payer
Don't select an accreditor until you've done your homework!
You may already be working with networks or third-party payers
that require accreditation. While CMS has identified 10
accreditors, your networks and payers may recognize only two or
three of them. Before making your final choice, check with your
payers and networks first to see if you are limited to certain
accreditors.
We would expect that of the accrediting organizations identified
by CMS that are able to meet the ongoing requirements, more payers
that have recognized only a few accreditors will recognize
additional accreditors as well.
Many providers make a selection based on fees, looking for the
least expensive. This can best be described as penny-wise and
pound-foolish.
As you review, you will find that many of the accreditors charge
fees that are within a few hundred dollars of each other. Most of
these organizations are non-profit, and while some may have
programs for accreditation of other services, those services do not
necessarily subsidize the cost of DME accreditation. All pay fees
to their surveyors, which average about $1,000 for the first day.
Additionally, the organizations have administrative costs to
cover.
This is not about cheap, this is about the relevance of the
program to your line of business and your ability to meet the
requirements without having to hire staff just to maintain your
accreditation.
While the accrediors have many similarities, there are several
with specific requirements you need to be aware of.
Is the accreditation for one, two or three years?
What, if anything, are the requirements for in-between
years?
How much ongoing time and staff effort is required? If you have
to hire a $40,000-a-year staff member just to maintain your
accreditation requirements, you have selected the wrong program.
However, if you are short-staffed and have to hire staff to
maintain a full-service, quality program, then you should not
consider these as costs associated with the accreditation
program.
Some of the organizations are more “tech savvy” than
others. Many require a paper process for providers to submit their
information, while others are very high-tech. If you don't know (or
want to know) how to turn on a computer, an electronic program is
not for you. This is not the time to learn.
Narrow your search to two to three organizations, and then start
a dialog with them. Note that if you can't reach an organization
while you're looking, you'll most likely not be able to get help
when you need it to get your questions answered.
Your Peer's Experience
Talk to your peers. Ask if they were satisfied with the
accreditor they chose, the process, the surveyors who came and the
outcome.
I've never met anyone who thought their accreditation was a
waste of time. All feel that it brought value to their business and
was a worthwhile endeavor. But I've met MANY providers who were
unhappy with their accreditor and changed to another at their
renewal.
You should also ask your accrediting organization for references
of similar providers who can explain how their experience was with
the organization. Every accrediting organization (that has not been
recently formed) can provide you with a list.
Shop Around
Unfortunately, when CMS gave us the 10 deemed status
accreditors, they did not give us a standardized list of products
and services by which we can compare them to each other.
The listing that follows has been prepared in an effort to help
you see which accreditor is an option for your company based on the
products and services you provide. All have approval to accredit
both local and national providers as well as those providing
supplies via mail order.
In addition to information provided on the accreditors' Web
sites for this article, each of the 10 organizations was asked to
provide the following information:
Inception
Length of accreditation term
How fees are calculated
Expected length of time for the program from application to
completion
If the program is new, how it has been tested. If the program is
not new, what (if any) substantive changes were made in order to
achieve CMS approval.
Not every accreditor responded to this request. These
organizations may not quote the price you will be charged for
accreditation if it is based on variables such as size, number of
sites, volume of sales/rental, etc.
Contact the accreditors you are considering for an exact quote
of the fees charged (for all that apply) including application,
purchase of their standards manual, annual fees, renewal fees,
surveyor expenses and any other fees involved. And, be sure to stay
on top of this information as CMS may change requirements or add
additional products to their list at any time.
With more than 25 years' experience in management throughout the
health care continuum, Mary Ellen Conway is the president of
Capital Healthcare Group, LLC, Bethesda, Md., where she specializes
in operations and regulatory issues in home health, hospice,
medical equipment and accreditation. She can be contacted by phone
at 301/896-0193 or through www.capitalhealthcaregroup.com.
Deemed Accreditation Organizations
(listed alphabetically)
Accreditation Commission for Health Care, Inc. (ACHC)
www.achc.org
Products: Full DME, Respiratory, Rehabilitation, Custom
Orthotics and Prosthetics
Established: Nationally in 1996
Accreditation term: Three years
Fees: Base is $3,800 complete per site per survey day.
Numerous association discounts in place that can lower the cost to
$3,500
Time to complete program: From two months as long as
appropriate policies and procedures are in place
Program changes: Adapted all CMS standards to further
simplify the overall process
American Board for Certification in Orthotics and Prosthetics
(ABC of O&P)
www.abcop.org
Products: Seven, including: 1) Comprehensive Orthotic and
Prosthetic Accreditation; 2) Prefabricated Orthotics; 3) Off the
Shelf Orthotics; 4) Post-Mastectomy; 5) Comprehensive Pedorthic; 6)
Non-Custom Therapeutic Shoe; 7) Ancillary Assist Device, includes
non-powered mobility devices but is only available as addition to
organizations completing products 1, 2 or 5
Established: First accredited facilities in 1948
Accreditation term: Three years
Fees: Example, Post Mastectomy Provider: $325 application
fee; $500 survey fee; $600 annual fee for each of three years (may
be prorated in year one as year runs from December-November)
Time to complete program: From two to six months
Program changes: Redefined categories and types to be
clearer and to match CMS product categories
The Board for Certification in Pedorthics (BCP)
This organization has merged with the American Board for
Certification in Orthotics and Prosthetics. The facility
accreditation process and application are being redesigned to
assure compliance with the Deemed Provider requirements. See ABC of
O&P.
Board of Orthotist/Prosthetist Certification (BOC)
www.bocusa.org
Products: Five, including: 1) Supplier providing a full
range of orthotics and/or prosthetic services; 2) Supplier limited
to fitting prefabricated orthotics devices, prefabricated
therapeutic shoes, arch supports, prefabricated post mastectomy
prostheses supplies; 3) A supplier that provides prefabricated
HME/DME products and services; 4) A supplier limited to fitting
prefabricated post mastectomy products and related supplies; 5) A
supplier limited to custom and prefabricated shoes, arch supports
and orthotics devices allowed within the scope of a licensed and/or
certified pedorthic practice.
Established: 1984
Accreditation term: Three years
Fees: $1,475 due with completed application (for four or
less locations) as application and accreditation fee; $750 survey
fee; additional $750 survey fee for more than two locations or
locations greater than 50 miles from original facility; annual
renewal fee $575 for first four locations, $375 for each additional
location.
Time to complete program: Not clear yet with integration
of CMS quality standards
Program changes: Unannounced on-site surveys were added
to program
Commission on Accreditation of Rehabilitation Facilities
(CARF)
www.carf.org
Products: DMEPOS covered by CMS Rehabilitation and
Customized Orthotics and Prosthetics Sections as well as specific
items such as wheelchairs, prosthetic devices, therapeutic
shoes
Established: Accepting applications after the final rule
on competitive bidding for DMEPOS is released
Accreditation term: Three years, but one year or
provisional accreditation may be awarded in some cases
Fees: $2,950 per location, which includes a standards
manual, off-site review of the self-evaluation form and other
materials, the on-site verification (including surveyor travel and
accommodations), the accreditation decision, and survey findings.
DMEPOS accreditation may not be blended with other CARF
programs.
Community Health Accreditation Program (CHAP)
www.chapinc.org
Products: Full DME, Respiratory, Rehabilitation, Custom
Orthotics and Prosthetics
Established: 1965
Accreditation term: Three years
Fees: Depends on size and scope of service. Generally
starts at $4,600, includes one site visit day and includes
standards; paid in four interest-free periods over the three-year
cycle
Time to complete program: CHAP provides organizations
with a self-study that the provider completes and then submits for
review. Length of time to complete the written materials varies by
organization, but averages at least two months. Once the completed
self-study is approved by CHAP, surveys are scheduled within 60
days.
Program changes: No changes
The Compliance Team, Inc.
www.exemplaryprovider.com
Products: Include Solo Practitioners (PT, OT,
Podiatrist), Boutique Pharmacies, Mail Order, Full Service
Pharmacies, Full DME, Respiratory, Rehabilitation, Custom Orthotics
and Prosthetics
Eestablished: 1998
Accreditation term: Initial sign-up period is for two
years plus orientation. At the end of the initial sign-up period,
the program renews on an annual basis.
Fees: Based on the types of products and services offered
and on the number of stand-alone locations a provider has that can
be reviewed in a single day
Range starts from $3,500 (for solo practitioners, e.g.,
podiatrist) to $6,900 (full service DME, pharmacy). Travel expenses
additional with all fees, initial and renewal. After two years,
annual renewal fees range from $1,495 to $1,995 plus travel
Time to complete program: Three months or less, although
most take at least four months
Program changes: Minor revisions
Healthcare Quality Association on Accreditation (HQAA)
www.hqaa.org
Products: Full Service DME, Respiratory, Rehabilitation,
Retail Pharmacies with DME, Retail Pharmacies with Limited DME and
Custom Orthotics. Providers complete administrative standards and
then select the products and services they provide such as Clinical
Respiratory, Rehabilitation, Delivery, Retail Services and Mail
Order.
Established: 2004
Accreditation term: Three years
Fees: Based on number of sites, size of organization. Can
be immediately provided for individual organization on the HQAA
website at
target="_blank">www.hqaa.org/pricing_structure.asp.
Time to complete program: Generally three months. Process
is completely paperless as a Web-based system that is available
24/7.
Program changes: Program was reviewed and some standards
were consolidated, thus making it more streamlined.
The Joint Commission (formerly JCAHO)
www.jointcommission.org
Products: Full DME, Respiratory, Rehabilitation, Custom
Orthotics and Prosthetics
Established: Hospitals in 1951, Home Care in 1988
Accreditation term: Three years
Fees: Spread over three years, starts at $3,500 for
small, single-site providers.
Time to complete program: Six months
Program changes: CMS standards matched in intent, so no
standards have been added
National Association of Boards of Pharmacy (NABP)
www.nabp.net
Products: Diabetic Equipment and Supplies, Enteral and
Parenteral Nutrients, Therapeutic Shoes, Mobility Aids (crutches,
walkers, canes, commodes), Wound and Ostomy Supplies, Urological
Supplies, Off the Shelf Medical Supplies, Nebulizers, CPAP and
Supplies
Established: First organizations will be surveyed in
2007
Accreditation term: Three years
Fees: Example, Single-site pharmacy ($2,145); application
fee (Year One) $375; annual fees $150/year; one-day survey
$1,500
Time to complete program: Once completed information is
received at NABP, goal is to complete the process within 30 to 45
days
National Board of Accreditation for Orthotic Suppliers
www.nbaos.org
Products: Accredits facilities that supply
custom-fabricated/made orthoses, custom-fitted orthoses, and
prefabricated orthoses to Medicare beneficiaries. Accreditation
available to facilities in which occupational therapists and
physical therapists provide orthoses.
Established: September 2006. Program created by The
American Society of Hand Therapists (ASHT) and the Hand Therapy
Certification Commission (HTCC).
Time to complete program: Program is new and there is no
information on test sites or trials. Explanation of process is as
follows: Once initial application is completed and submitted with
the fee, organization performs a self-assessment and a test survey.
When organization feels that it has satisfactorily completed all
requirements, documents are returned and application is processed.
The surveyor plans on-site survey within 45 days of receipt.
Note: At press time, CMS' final rule on national competitive
bidding had not been issued. For updates, contact Mary Ellen Conway
at www.capitalhealthcaregroup.com.
Comparing Apples to Apples
Accreditation Commission for Health Care, Inc. (ACHC)
DME Group 1
DME Group 2
Medical Supplies
Respiratory
Rehabilitation
Custom Orthotics and Prosthetics
American Board for Certification in Orthotics and Prosthetics
(ABC of O&P)
DME Group 1 (as long as Custom Orthotics and Prosthetics program
is being completed)
Custom Orthotics and Prosthetics
Board of Orthotist/Prosthetist Certification (BOC)
DME Group 1
DME Group 2
Medical Supplies
Respiratory
Custom Orthotics and Prosthetics
Commission on Accreditation of Rehabilitation Facilities
(CARF)
Rehabilitation- Manual and Power Wheelchairs
Custom Orthotics and Prosthetics
Community Health Accreditation Program (CHAP)
DME Group 1
DME Group 2
Medical Supplies
Respiratory
Rehabilitation
Custom Orthotics and Prosthetics
The Compliance Team, Inc.
DME Group 1
DME Group 2
Medical Supplies
Respiratory
Rehabilitation
Custom Orthotics and Prosthetics
Healthcare Quality Association on Accreditation (HQAA)
DME Group 1
DME Group 2
Medical Supplies
Respiratory
Rehabilitation
Custom Orthotics
The Joint Commission (formerly JCAHO)
DME Group 1
DME Group 2
Medical Supplies
Respiratory
Rehabilitation
Custom Orthotics and Prosthetics
National Association of Boards of Pharmacy (NABP)
DME Group 1
Medical Supplies
Rehabilitation (POV's only)
Orthotics (Therapeutic Shoes Only)
National Board of Accreditation for Orthotic Suppliers
Custom Orthotics and Prosthetics
Definitions of Groups
DME Group 1 - Mobility Aids: Manual Wheelchair, Cane,
Walker, Crutches, Stationary Commode Chairs, Wound Care and Ostomy
Supplies
Urological Supplies: Bedpans, Urinals
Client residence visits performed on survey? Yes, if
items are rentals. If not on rental, No
DME Group 2 - Manual and Electric Beds, Traction
Equipment
Client residence visits performed on survey? Yes
Medical Supplies - Diabetic Supplies, Enteral Products
(Non-home visit items)
Client residence visits performed on survey? No. Client
interactions observed and paperwork reviewed.
Respiratory - Home medical equipment and supplies covered
in this group include Respiratory equipment and supplies, Oxygen,
Oxygen concentrators, reservoirs, conserving devices, high-pressure
cylinders, oxygen accessories and supplies, home invasive
mechanical ventilators, respiratory assist devices, continuous and
intermittent positive pressure breathing devices, nebulizers
Client residence visits performed on survey? Yes
Rehabilitation - Items covered in this group apply to
Manual Wheelchairs, Power Mobility Devices (PMDs), including
Complex Rehab and Assistive Technology. PMDs include power
wheelchairs and power operated vehicles (POVs) and accessories.
Manual Wheelchairs include standard recliners, heavy-duty
wheelchairs, standard lightweight wheelchairs, and hemi
wheelchairs, armrests, leg rests/footplates, anti-tipping devices,
and other Medicare-approved accessories.
Client residence visits performed on survey? Yes, if
items are custom and if items are on rental
Orthotics and Prosthetics - Items included in this group
include custom fabricated, custom fitted, custom-made orthotics,
prosthetic devices, somatic, ocular and facial prosthetics, and
therapeutic shoes and inserts, leg, arm, back, and neck braces,
artificial legs, arms, and eyes, and extra-depth shoes with inserts
or custom-molded soles with inserts (therapeutic shoes).
Client residence visits performed on survey? Yes, but
depending on items provided (e.g. therapeutic shoes only), may
observe patient interaction and/or record review alone.
