The Inevitable Question

In these last few months preceding the Oct. 1 CMS deadline to be accredited, there is a massive crush of HME providers who have finally begun the process. Thus, the questions are flying. And often, the question is, “Why do we have to do that?”

One of the most common questions is, “Do we have to track staff and customer infections?” The answer is yes. But, providers say, “We don’t have any idea whether or not a staff member is sick with an infection or of the patient has an infection. Why do we have to do that?”

In this particular situation, the CMS Final Quality Standards included this new requirement in revisions that were released in October 2008. I’m sure the philosophy behind this requirement is that providers would find out whether their infection control processes are adequate if they were to track such infections.

If, for example, a provider found that customers on one driver’s route were the ones who were reporting illnesses, the company would realize that this driver could be lax in proper infection control practices and might be making his or her customers sick. Or that cleaning processes were insufficient. Or that staff contracting illness might be those who were not washing their hands adequately or not using personal protective equipment such as gloves routinely.

Tracking this information would help a provider identify these types of problems. Just because a supplier doesn’t provide many items, may not deliver items or may not even have rental items (as many pharmacies do not), it does not remove the requirement. But maintaining a simple log meets this requirement and is an easy process to implement.

Another common concern is from small providers: “There are only three employees here; we aren’t big enough to need a disaster plan.” This could not be further from the truth. We all know that natural disasters and emergencies do not discriminate.

Both small and large suppliers are affected by disasters such as hurricanes, tornadoes, floods and power outages. I recently saw a billboard in the rural mountains of West Virginia that said “One in four businesses do not recover from a disaster — make a plan.”

Every HME provider needs a plan for what to do in the event of a disaster. It is common sense to back up data systems routinely, but even more important to have done so in the event of a disaster. Copies of staff contact information should be kept at an owner’s or manager’s home; there’s no value in a plan that is kept at the office when you can’t get to the office to use it.

Every provider needs to be prepared for emergencies and have a fire drill annually to ensure that the staff can evacuate the facility safely. Exit signs must be posted, exit routes identified, and a safety officer must ensure that the staff is prepared adequately. It doesn’t matter how small a home care company is; a small provider is as responsible for the safety of the staff as much as a large provider is. Each must adequately prepare for the recovery of the business in the event of a disaster.

A third issue often asked about by complex rehab providers is, “I don’t need a full time employee as a Certified Rehab professional. We do a small amount of this type of service. I don’t have enough to keep someone busy full time and, thus, want to employ an independent contractor.”

Again, the October 2008 revisions to CMS’ Final Quality Standards require that provides utilize W-2 employees, not independent contractors, in these positions, whether or not the provider needs this service full-time or part-time. Even if the individual meets the IRS requirements to be an independent contractor, CMS requires that he or she be a W-2 employe, and accrediting organizations are required to check to ensure that this is in place.

The lesson is that all accreditation requirements apply to all companies. If you think any of the accreditation standards do not apply to your company, then you need to consult with your individual accreditor in plenty of time — prior to your on site survey — to ensure that your company is meeting all necessary requirements.

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. You can reach her at 301/896-0193 or through www.capitalhealthcaregroup.com.