ATLANTA--In a disconcerting surprise to many home medical equipment providers, those that service hospices must be accredited by Dec. 2, 2008, in order to keep their contracts, according to the finalized “Conditions of Payment” for Medicare and Medicaid hospices published recently in the Federal Register.
The COP, published June 5 and effective Dec. 2, stipulates that a hospice may only contract with a durable medical equipment suppplier that meets the Medicare DMEPOS Supplier Quality and Accreditation Standards at 42 CFR 424.57.”
That standard, noted in the special payment rules for items furnished by DMEPOS suppliers, defines accredited DMEPOS suppliers as “suppliers that have been accredited by a recognized independent accreditation organization approved by [the Centers for Medicare and Medicaid Services] in accordance with the requirements at Sec. 424.58 [of the “Conditions for Medicare Payment” for DMEPOS providers].
News of the accreditation requirement, which has dribbled out as hospices have alerted their HME suppliers, has panicked some providers, according to accreditation consultant Mary Ellen Conway, president of Capital Healthcare Group, Bethesda, Md.
“We’ve been getting tons of calls from people being contacted by hospices saying they have to be accredited,” Conway said. “I’m concerned about the number of people who have called to clarify the information and find out what they need to do to get started now.”
While some providers serving hospices are already accredited, many were shooting for the Sept. 30, 2009, mandatory accreditation deadline set for all DMEPOS providers by CMS last year. But under the new rule, for providers contracting with hospices, that deadline will not work.
“For a DME that has hospice as … a major portion of their revenue stream, this is an enormous requirement,” Conway said. “It’s fine if a provider is already accredited, but based on the number of calls we’ve gotten, it could be a problem.” State hospice surveyors, she added, “are going to be looking for that requirement of only dealing with accredited providers by that Dec. 2 date.”
Bob Floro, MSL, RRT, director of the home care accreditation program for The Joint Commission in Washington, D.C., said his accrediting organization has already gotten calls from providers seeking accreditation in order to service hospices.
“I just fast-tracked somebody last night,” he said, adding that he expects calls to increase as more and more hospices communicate the new standard to their HME providers.
Floro said it is possible for his organization to accredit a provider by the Dec. 2 deadline.
“It’s doable. There’s a very, very tight window. The surveys have to be done by October or maybe the first week in November to meet the deadline,” he said. However, he pointed out, it’s only doable if a provider understands the level of preparation it takes to become accredited and accomplishes that in two months.
Gwen Franzgrote, director of HME services for the Washington, D.C.-based Community Health Accreditation Program, said she has also received inquiries about DME accreditation to supply hospices.
“For those that are starting now, it is possible to get through the process,” she said, “but I would not encourage them to wait much longer.”
Hospices will want to be found in compliance by that Dec. 2 date, she stressed. They are thus unlikely to continue their association with HME providers who are not accredited.
Tom Caesar, president of the Raleigh, N.C.-based Accreditation Commission for Health Care, said his organization has so far received just a few e-mails on the accreditation issue. He is doubtful that ACHC would be able to accommodate any but the most prepared of providers applying now for accreditation by Dec. 2.
“We are scheduling 400 surveys right now,” he said, so the organization’s priority is to those providers already in the pipeline for accreditation. HME providers shooting for the Dec. 2 deadline, he said, “have to be ready like now, and then we can put them on as quickly as possible.”
He pointed out the probability that this won't be the only accreditation deadline to pre-date the CMS mandatory deadline. Some state Medicaid agenicies are considering or have already established their own accreditation deadlines, both he and Conway said. Conway also noted the Jan. 1, 2009, accreditation deadline “that is sneaking up fast” for providers who were enrolled with the National Supplier Clearinghouse before March 1, 2008. (Providers who enrolled on or after March 1 must already be accredited.)
“Frankly, for the folks who do DME Part B, a lof of them have waited and waited and waited to get accredited. And it’s going to work against them,” Caesar said.“The guys in the DME world might as well get accredited.”
To view the final rule for hospices, click here and scroll to section 32212 (page 126 of the PDF) for 418.106 "Condition of participation: Drugs and biologicals, medical supplies, and durable medical equipment."