Medicare Made Me Do It

Even though many providers are new to accreditation, the accreditation process has been around for years. It had always been a voluntary process that providers “chose.” But many felt they didn’t really have a “choice,” since managed care and Veteran’s Administration contracts limited enrollment only to accredited providers. And in some cases, only one accreditor (JCAHO, The Joint Commission) was recognized. So, while accreditation was technically a voluntary process, it seemed mandatory for many.

We know that the Medicare Modernization Act of 2003 requires all DMEPOS providers billing Medicare to be accredited by Sept. 30, 2009, thus ensuring that this is no longer a voluntary process. And CMS has not limited the selection of accreditors to just one or a few organizations as some payers do. There are 10 accreditation organizations, some old and some new, that Medicare recognizes.

Even with the Medicare accreditation requirement, however, some providers still are unclear about the processes, believing that they are only required to implement the accreditor’s standards for their Medicare beneficiaries. But this is not true. Accreditation requirements are for all of the HME company’s customers.

Think about the providers who have been accredited for years. They have implemented policies and procedures to meet their accreditation organization’s standards.

Let’s say, as an example, that the ABC Managed Care Plan requires accreditation for all DME suppliers. Joe’s DME decided to become accredited back in 1990 and then, in 1992, became one of the contracted suppliers for ABC. When an ABC customer is referred for DME items such as oxygen, a hospital bed and a walker, Joe’s verifies the customer’s enrollment and contacts him or her to make the delivery.

Joe’s staff makes the delivery to the customer’s home ensuring that the company’s vehicles are compliant, segregating clean and dirty items within the vehicle. The staff uses personal protective equipment (PPE), maintaining infection control guidelines at all times.

The staff member, who has been competency-trained to do so, sets up each piece of equipment and trains the beneficiary on its use. The staff member orients the customer to Joe’s processes, provides the customer with his or her rights and responsibilities, how to reach Joe’s during and after business hours and how to file a grievance. Joe’s includes this customer in the quality improvement program and sends out a customer satisfaction survey.

This is the process Joe’s performs for all of its customers, not just those who are ABC beneficiaries. For the customer coming to Joe’s who is a Medicare beneficiary, Joe’s staff ensures they are performing all of the same processes that they did for the ABC beneficiary. But for this customer, Joe’s is also providing the customer with a copy of the 21 — soon to be 25 — Supplier Standards (a Medicare requirement). And since the customer got a walker, it is Joe’s policy for Medicare beneficiaries to get an ABN signed and to provide information on inexpensive or routinely purchased items.

Medicare beneficiaries in a nursing home do not get different services because they are Medicare beneficiaries, and Medicare requires that the facility be accredited. There may be certain length-of-stay issues or items that are included in a per diem payment, but the services themselves do not change.

Similarly, Joe’s doesn’t maintain infection control processes just for their ABC customers, or only educate those customers on their equipment because ABC required that Joe’s be accredited. Likewise, providers getting accredited because of the Medicare requirement implement and maintain the same processes for all of their customers.

In many ways, it can seem like we are trying to fit a square peg into a round hole. Since Medicare is requiring that providers become accredited, it may confuse those who think these processes are only applicable to Medicare beneficiaries. But when they review the expectations and think about the requirements, they soon realize they would implement their processes for all customers and treat all customers similarly.

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.