ATLANTA--After announcing Sept. 30, 2009, as the deadline by
which all DMEPOS providers must be accredited, CMS officials at an
Open Door Forum Dec. 19 refused to give out information on
additional dates. But the accreditation deadlines for new suppliers
were revealed just two days later in a list serv for
pharmacists--and the dates are raising questions.
According to the list-serv notice, sent Dec. 21 and confirmed by
HomeCare Monday through CMS' Office of the Administrator,
DMEPOS suppliers who enroll with the National Supplier
Clearinghouse (NSC) before March 1, 2008, will have until Jan. 1,
2009, to obtain accreditation. On or after March 1, 2008, those
seeking NSC enrollment must be accredited prior to submitting an
application.
The latter stipulation--requiring that providers be accredited
before submitting an application to receive an NSC number--has
raised some issues.
"[Becoming accredited] includes gathering data on your Medicare
beneficiaries, but how can you gather data on billing and
collections and beneficiary satisfaction if you don't have any
beneficiaries?" questioned industry consultant Mary Ellen Conway,
president of Capital Healthcare Group, Bethesda, Md. In addition,
she pointed out, "You can't become a Medicaid provider until you
have acquired your Medicare number, so no Medicaid patients,
either."
Mary Nicholas, executive director of the Waterloo, Iowa-based
HealthCare Quality Association on Accreditation--one of 10
accrediting organizations approved by CMS--said she is awaiting
clarification from the agency on exactly how getting accredited
prior to receiving an NSC number would work, but she fears such a
process might have a chilling effect on HME.
"I am concerned for the growth of the industry," Nicholas
said.
While the requirements for new suppliers have generated new
questions, the "drop-dead" accreditation date of Sept. 30, 2009,
has rekindled old concerns. The deadline may be 21 months away, but
accreditors and consultants are already warning HME providers not
to drag their feet. Any delay could cause last-minute applicants to
be left out in the cold, they said, especially with the second
round of competitive bidding looming.
Although she is relieved CMS has allowed a "manageable" amount
of time for existing providers to complete the accreditation
process, "you may not have as much time as you think," Conway
cautioned. "Accreditation generally takes between four and six
months, and part of that has to include time for the unannounced
survey, which can take another 45 to 90 days.
"Plus," she continued, "if CMS announces the next 70 MSAs
anytime soon, there will certainly be a deadline in those MSAs in
order to bid, and that deadline will come well before the Sept. 30,
2009, deadline."
HQAA's Nicholas agreed. "If the past year was any indication of
the 'norm' or typical behavior of the [HME] population, then there
will be a last-minute rush for accreditation. There were people
calling us in July trying to make the August deadline [for
first-round bidders].
"Please remember you must allow yourself enough time to complete
the accreditation journey," she advised providers.
"Many companies have been dragging their feet to see when the
deadline was going to be," Conway said. "Now they have no
excuse."
According to a recent survey of HomeCare readers, 43
percent of the HME providers polled (before the CMS announcement)
remain unaccredited. Of those, 29 percent said they planned to
apply in 2008, another 5 percent in 2009, and another 16 percent
"when CMS requires it for all providers."
The number of unaccredited providers coupled with other factors
could create something of a scramble, accreditors said.
Unaccredited providers in CMS' anti-fraud demonstration areas in
south Florida and southern California must gain accreditation
within 120 days of notice that they must reenroll in the Medicare
program. (See
Homecare Monday, Nov. 5.) And providers in all of the
country's big cities should begin the process immediately with CMS
expected to ramp up Round Two of competitive bidding at any time,
accreditors said.
"If you're living in one of the nation's top 100 biggest cities
and you weren't included in the first round, you can pretty much
guarantee that you'll be included in this round," said Sandra
Canally, president of The Compliance Team, Spring House, Pa. "Don't
keep waiting for CMS to make the announcement. If you're in
Atlanta, you're going to be part of it. If you're in L.A., it's
coming. So many people still have their heads in the sand thinking
that this is going to go away, and it's not."
According to Canally, HME inquiries have increased since the CMS
deadline announcement, but she worries many of the industry's
providers do not understand the gravity of the timetable.
"They don't understand that this is so far-reaching," she said.
"Accreditation affects podiatrists, physical therapists,
occupational therapists, physicians--even people who provide
corrective lenses. Anybody who bills anything DME-related to Part B
comes under this mandate. So when they set the deadline of Sept.
30, 2009, we're not talking about just providers within the DME
industry who need to become accredited.
"The 10 accrediting bodies are going to have to look at up to
100,000 providers by the deadline date," Canally said.
Despite the potential for an accreditation crunch, Conway said,
"if you apply right now, you should have plenty of time. But the
more you delay, the more problems you may have."
A list of the 10 CMS-approved accreditation organizations can be
viewed online at
www.cms.hhs.gov.
