Give Us the Date!

You have no doubt read about the most recent meeting with CMS and the competitive bidding Program Advisory and Oversight Committee that was held in Baltimore on Oct. 11. Many items were reviewed regarding questions from the first round of competitive bidding and concerns about the approaching second round. One of the key concerns was provider accreditation.

Sandra Bastinelli is the CMS staff member charged with running the accreditation program. During the meeting, she explained how she has biweekly teleconferences with CMS’ 10 approved accreditors to keep them posted on the progress of providers in the first 10 competitive bidding areas. Bastinelli reported that 2,200 providers have been accredited across the 10 CBAs.

Here is a review of her presentation:

• Newly revised quality standards have been sent to the accreditors for review. These are intended to clarify the current standards, which were released in August 2006. Bastinelli said that providers would not have to update information on how they comply with any of the revisions. Once the standards are ready for publication, they will be posted at www.cms.hhs.gov/medicareproviders/supenroll and will be open for public comment.
• Bastinelli informed the PAOC that suppliers are required to identify the types of products they provide, and they are then accredited for those particular products. CMS’ identification was based on the top 60 billing categories in 2006.
• According to Bastinelli, the average cost per accreditation survey for providers in the first round is $2,500. She explained that this fee was quoted for a smaller-sized business with one location. She also said that this was not a “one-price-for-all” situation, noting, for example, that one large organization has 6,000 locations nationwide.
• Suppliers need to apply for accreditation when they are ready to receive their unannounced survey, Bastinelli said. She clarified that every accreditor has its own process and that some require application long before the unannounced survey. She also said that many providers were refusing entry to the accreditors for their survey. She reiterated that providers need to be ready to receive their survey and that a refusal of entry to a surveyor was equivalent to a refusal to become accredited.
• Bastinelli noted that accreditation and competitive bidding were intertwined. One member of the PAOC immediately stated that they, in fact, were not: Many providers might never have to participate in competitive bidding but all would have to be accredited. These comments were the basis for a discussion that followed about setting a deadline for provider accreditation.

Bastinelli explained that for phase two of competitive bidding, CMS is developing accreditation timelines that reflect supplier practices since there has been a general delay in suppliers beginning the accreditation process. Some members of the PAOC and the audience at the meeting said they felt that delay was based on the fact that CMS has not released a “drop-dead date” by which all providers will need to become accredited.

The PAOC members pointed out that with all of the high-profile fraud-and-abuse cases in the news, enforcing the accreditation requirement for all providers — rather than phasing it in with competitive bidding — would help to alleviate this situation.

Bastinelli explained that CMS had not yet set a drop-dead date despite industry rumors. Members of the PAOC and some public commenters said that rather than denying a rumored date, announcing the final date would be a great service to the industry and could push providers who procrastinate to get moving. Walt Gorski, vice president of government relations for the American Association for Homecare, commented that announcing the date is “the best way to reduce fraud and improve quality”.

Bastinelli encouraged providers to contact her with questions or concerns by e-mail at [email protected] or phone at 410/786-3630.

While we didn’t learn much that day in Baltimore, we can only hope that CMS will understand our need for that drop-dead date to be announced once and for all so that providers can include accreditation in their business plans.

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.