AAHomecare Faults CMS’ Proposed Quality Standards

ALEXANDRIA, Va.–In a letter to CMS Administrator Mark
McClellan, the American Association for Homecare called the
agency’s proposed quality standards for suppliers “overly
prescriptive” and urged the release of more details on
accreditation.

The 24-page letter outlines the organization’s concerns and
recommendations for the draft standards, which were released Sept.
23 by CMS and its contractor Abt Associates, Cambridge, Mass.
Expected to be finalized next year, the quality standards will be
required of providers in the 10 cities where Medicare competitive
bidding will begin in 2007–and eventually, of all DMEPOS suppliers
who want to do business with Medicare (see HomeCare
Monday, Sept. 26).

CMS’ draft document focuses on two areas: business standards and
product-specific requirements for items from oxygen and power
wheelchairs to commodes and canes.

These details go too far, AAHomecare said, recommending that CMS
eliminate detailed product standards for specific items and noting
that some standards duplicate those already required by federal,
state and local law. “CMS may have misunderstood the discussion by
the [Program Advisory and Oversight Committee] about the need for
product-specific standards. Certain lines of service such as
respiratory, rehab and assistive technology, or infusion require
specific standards to meet the needs of patients. This does not
mean that every item of DMEPOS requires its own special set of
standards.”

Furthermore, the standards leave little room for the provider to
exercise judgment when offering service, the association said.
“Standards should establish the benchmark that a provider must
meet, but should not be so specific that they dictate care or
service.”

In current form, the association continued, the standards are
more like a checklist or operating manual, which “dilutes the value
of accreditation.”

AAHomecare also urged CMS to reveal more details about how it
intends to implement mandatory accreditation. Agency officials have
previously indicated that providers who are already accredited may
have the opportunity to be grandfathered in, but have yet to issue
specific details. The uncertainty has made many providers hesitant
to begin the accreditation process, according to the association.
“A clear policy statement from CMS on this issue favors all
stakeholders and will encourage providers to seek accreditation
now, promoting a smooth transition when all the standards are
final,” the letter stated.

Other suggestions by AAHomecare include:
–clarifying the role of the National Supplier Clearinghouse so
providers are not subject to conflicting interpretations of
standards;
–developing definitions for some of the terms in the draft
standards and using them consistently. For example, “licensed,”
“certified,” “credentialed” and “qualified” are all used in the
same document, but no definition is given to differentiate the
terms;
–resolving inconsistencies with Medicare reimbursement, coverage
and billing requirements;
–eliminating the requirement that providers operate 40 hours a
week, as long as a provider maintains appropriate access for
emergency or an urgent after-hours contact;
–eliminating the blanket prohibition on using mail order delivery
for all medical equipment;
–modifying the requirement that a provider should respond within
60 minutes of a beneficiary service call;
–eliminating the requirement that providers maintain financial
records that comply with general accepted accounting
principles;
–eliminating the requirement that a provider notify CMS and its
accreditation organization when it first becomes aware of potential
adverse financial operations;
–eliminating the requirement that providers establish a service
plan for devices in Class I, which includes canes and walkers.

Comments on CMS’ proposed quality standards for suppliers are due
Nov. 28. A draft of the standards is posted at www.cms.hhs.gov/suppliers/dmepos/compbid/default.asp.
Submit comments to [email protected].