Deadlines and Deliverables

For the past few summers, it seems that just when we were ready to have a quiet season and enjoy the sun, the outdoors, the mountains and beaches, a new surprise from CMS has popped up to bring us back to reality. This summer’s wake-up call came in the form of news from Medicare-certified hospices.

The hospice community has been waiting for updates to the rules they follow, known as the “Conditions of Participation” or the “COP’s”. The draft updates to the COP’s were released over two years ago and then, this summer, those updates were published in final form in the Federal Register on June 5.

This update has many components that hospices need to incorporate, but one of the significant changes is found in a sentence that states: “Hospices may only contract for durable medical equipment services with a durable medical equipment supplier that meets the Medicare DMEPOS Supplier Quality and Accreditation Standards at 42 CFR § 424.57.” These rules become effective for hospices on Dec. 2, 2008.

Unfortunately, the DME community really wasn’t aware of this requirement right away. Most hospices only began contacting their DME providers in late July. At that time, providers started calling our offices in a panic because their hospice contracts were in jeopardy since they had not yet become accredited.

As we researched this regulation, we found that it was, in fact, true. The news quickly spread, and during an Aug. 13 Open Door Forum, callers asked CMS staff about this new deadline and why it conflicted with the Sept. 30, 2009, deadline for mandatory DMEPOS accreditation. Staff members were at a loss to answer the question and asked callers to request the information by email.

Then, in a true surprise, for the first time, CMS released a statement the following week to clarify the information. On Aug. 20, the statement released read:

“If a hospice has a contract with a DME (that has a Medicare supplier number), the hospice should have a letter in their file from the DME stating the DME has applied and is waiting for accreditation by the 9/09 date.

“If the hospice contracts with a DME that only serves hospice, (therefore no Medicare supplier number), the hospice will need to make sure the same type of letter from the DME is in place in their files. The accrediting bodies are aware that these DME’s serving hospice only will be calling for accreditation.

“If the hospice owns its own DME, then no accreditation is needed.”

This statement augments what appears to be the requirement in the COP’s. It looks like the guidance CMS will give the state health department surveyors who review hospices for compliance with the COP’s is that the DME must be in process by December of 2008. This certainly makes sense, given that the “drop dead” date of Sept. 30, 2009, is what CMS has been focusing on.

While it would appear that the right hand had no idea what the left hand was doing at CMS, the bigger issue here is that this is yet one more reason you should have been accredited already. Why would you be waiting for deadlines to get so close? Are you a perpetual procrastinator?

If you’ve ever read this column or listened to presentations or teleconferences on accreditation, you know that CMS is not your only payer. Blue Cross and other third-party payers have mandated accreditation deadlines much sooner than that set by CMS. Even Medicaid programs in various states have required accreditation for their participating providers.

Given that this new date caught providers off guard — even though the information was subsequently clarified — this should be the last time you are surprised with an accreditation deadline. Stop waiting, begin the process and get it behind you. As business costs go up, accreditation expenses also rise with the increased cost of travel and administration.

Snap out of the quiet of summer and get going! Get accreditation out of the way before another deadline and deliverable pops up out of the blue. There is just no excuse to be caught off guard again.

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.