Fasten Your Seatbelt

We hit the ground running in DMEPOS accreditation with the start of 2008. The updates are still coming fast and furious, and it seems like every week there’s more information from CMS to digest. Not that the information is always the easiest to understand, but there is a lot happening, and we need to review what we know so far.

As announced in December, all DMEPOS providers planning to bill Medicare for identified Part B products and supplies must be accredited by Sept. 30, 2009. In January, we learned the next 70 MSAs where round two of competitive bidding will occur. Some of the cities selected for this group were quite a surprise.

CMS explained that the MSAs in round one were selected because they are areas with the highest allowed DME charges, and that the round two MSAs were selected because they have the highest population.

Yet, this explanation for round two is baffling since there are major cities left off the list — including many that appeared on CMS’ original list of the “top 25 MSAs” from which the agency made its choices for round one. These cities include Boston, Seattle, Baltimore and others. CMS’ methodology falls short if one thinks areas such as Visalia, Calif., or Asheville, N.C., are larger than Seattle, Washington, D.C., or Boston.

CMS expects to follow a similar time line in 2008 for round two as it did last year for round one. This would logically mean that all providers in these next 70 MSAs would have to be accredited in order to bid — and that accreditation deadline (although it had not been announced as of press time) could be as soon as this summer.

While CMS also has not defined the zip codes in these MSAs, just assume that the areas are enormous. Providers who service beneficiaries residing in these areas should begin the accreditation process right away in order to have their unannounced survey completed in advance of any potential summer or fall 2008 deadlines.

Additionally, CMS continues to describe to Congress that the industry is rife with fraud. For an industry that accounts for about 1.7 percent of all Medicare dollars spent, it would appear that we have fraudulent providers on every block. The mandate for accreditation will certainly eliminate some of the fraudulent providers out there, but, sadly, it will also force some small providers out of business.

Which leads to discussion of the next deadline providers should be aware of. CMS also announced in December that all suppliers planning to open new locations must be accredited prior to obtaining a supplier number from the National Supplier Clearinghouse.

This information was amended during a CMS educational teleconference held Jan. 22. On that call, officials clarified that providers who already have 25 locations enrolled in the Medicare program would not have to obtain accreditation for new locations until the national deadline of Sept. 30, 2009.

On first blush, this new revision again seems to reward large providers and punish small providers. Truly, the greater risk of fraud seems to be with a provider who can open up shop and then quickly relocate before the trail of fraud catches up with them. Unfortunately, this revision penalizes all small providers and limits their ability to compete in additional markets.

Clearly, more work needs to be done with CMS to review the time frame for obtaining a new supplier number: Providers cannot have accreditation reviews to meet quality standards if they have no beneficiaries to serve.

There will be additional announcements as the calendar, and round two of bidding, move forward, so listen to the educational sessions CMS is offering on accreditation (the next one is scheduled for April 17), phone in with your questions, participate in CMS Open Door Forums, speak with your congressional representatives to educate them on what is happening — and get accredited as soon as you can. This is not a time to sit back and watch to see what happens next.

So fasten your seatbelt. It’s going to be a bumpy ride.

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.