AAHomecare Faults CMS’ Proposed Quality Standards

Alexandria, Va.

In a letter to CMS Administrator Mark McClellan, the American Association for Homecare called the agency’s proposed quality standards for suppliers “overly prescriptive.”

The 24-page letter outlines the organization’s concerns and recommendations for the draft standards, which were released Sept. 23 by CMS and its contractor Abt Associates, Cambridge, Mass. Expected to be finalized next year, the quality standards will be required of providers in the 10 cities where Medicare competitive bidding will begin in 2007 — and eventually, of all DMEPOS suppliers who want to do business with Medicare.

CMS’ draft document focuses on two areas: business standards and product-specific requirements for items from oxygen and power wheelchairs to commodes and canes.

These details go too far, the association said, recommending that CMS eliminate detailed product standards for specific items.

AAHomecare also urged CMS to reveal more about how it intends to implement mandatory accreditation. Agency officials have previously indicated that providers who are already accredited may have the opportunity to be grandfathered in, but have yet to issue specific details. The uncertainty has made many providers hesitant to begin the accreditation process, according to the association.

Other suggestions by AAHomecare include:

• clarifying the role of the National Supplier Clearinghouse so providers are not subject to conflicting interpretations of standards;
• developing definitions for some of the terms in the draft and using them consistently;
• resolving inconsistencies with Medicare reimbursement, coverage and billing requirements;
• eliminating the requirement that providers operate 40 hours a week;
• eliminating the blanket prohibition on using mail order delivery for all equipment;
• modifying the requirement that a provider should respond within 60 minutes of a beneficiary service call;
• eliminating the requirement that providers maintain financial records that comply with general accepted accounting principles;
• eliminating the requirement that a provider notify CMS and its accreditation organization when it first becomes aware of potential adverse financial operations; and
• eliminating the requirement that providers establish a service plan for devices in Class I, which includes canes and walkers.