Mandatory Accreditation

Since the late 1980s, accreditation has been voluntary for home medical equipment providers in the Medicare program. But this is about to change. The Medicare Prescription Drug, Improvement, and Modernization Act of 2003 requires all durable medical equipment suppliers, along with home infusion service providers, to become accredited to maintain their Medicare supplier number.

Although the time frame for implementation has not been outlined, providers should start to think about accreditation — and begin the process.

Though not complex, the accreditation process does take time. It can be more than a year from the time you decide to become accredited until you receive the actual certificate.

Presently, it takes a minimum of six weeks for the accreditation bodies to schedule a survey — and this is with today’s demand. Providers should anticipate that, as the CMS deadline draws near, the backlog for surveys will probably increase.

Getting Started

The first step is determining which accrediting organization is right for your company. This is not a one-size-fits-all process, and each accrediting body is unique. By visiting their Web sites, you can learn how each handles the process, including policies and procedures.

The Joint Commission on Accreditation of Healthcare Organizations (JCAHO) currently does not require any self-assessment before the first survey, while the Accreditation Commission for Healthcare (ACHC) and the Community Health Accreditation Program (CHAP) both require preliminary documentation, and both allow six months to prepare and submit this material. JCAHO has announced that it will require a self-assessment document in mid-cycle, rather than before the initial survey.

Second, check with payers and contractors to see if they have any accreditation requirements and if they recognize all three accrediting bodies. Third, look at the frequency of surveys. All accrediting bodies have a three-year cycle, and all three organizations may do random, unannounced surveys at mid-cycle. Besides these, JCAHO and ACHC do surveys once every three years, while CHAP may conduct surveys as frequently as annually based on recommendations of its Board of Review.

Look at Costs and Standards

Another consideration is cost. Both JCAHO and ACHC have a one-time flat fee based on an organization’s size. There are no additional charges for surveys or travel expenses for surveyors. CHAP has an annual fee based on an organization’s size, and a fee for each survey day. If there is only one survey conducted in the three-year cycle, there would be only one survey fee; however, if the Board of Review requires additional surveys, there would be additional cost.

Consider how frequently the accreditors update their standards to keep up with changes in the industry. Also, make sure the accreditor’s standards will not require you to totally revise the way you operate your business. To become accredited, you must comply with all HME standards from an accrediting body; you can’t pick and choose the standards with which you want to comply.

Accreditation is not a solo activity for the company owner or manager. The ultimate goal of accreditation is to improve business operations and assure that quality care is provided to clients. For this reason, the process should involve as many team members as possible to assure smooth implementation of any changes and make certain that everyone understands the importance and relevance of accreditation.

If preparing for ACHC or CHAP, the Preliminary Evidence Review (ACHC) or the Self-Study (CHAP) must be completed and submitted before the survey is scheduled. In order to complete these documents, divide standards in the accreditation manual among team members. Give each responsibility for assuring compliance and providing the necessary documentation for a group of standards.

This is your opportunity to make sure the company is in compliance with all the standards before submission of the document, and allows time to correct any deficiencies prior to the on-site survey.

Even though JCAHO does not require this preliminary document, you should still sit down with the team and review all standards in the manual to determine how your company will demonstrate compliance to the surveyor.

Each of the accreditation manuals not only lists the applicable standards but also outlines documentation that is required to demonstrate compliance with that standard. Also note that there is more than one way to meet a standard. The standards should be looked at as a “cookbook” to help improve business operations, as well as outlining how to improve the quality of care provided.

Some suppliers decide to bring in outside help at this point to assist in the preliminary evidence review and/or to perform a mock survey. This is often the case when there is not adequate staff time to do the necessary preparation.

After gathering and, if required, submitting preliminary evidence, a survey date will be set. At present, all three accrediting bodies announce their surveys, although beginning in 2006, JCAHO’s surveys will be unannounced.

Between scheduling of the survey and the survey itself, it is important to assure all new processes that were changed or added during the preliminary evidence reviews have become part of daily operations. Surveyors will want to validate that all information contained in the self-study, preliminary review or application accurately represents how you conduct business.

The length of the survey and number of surveyors is determined by company size. Small companies could have a one-day survey with one surveyor, while large companies with multiple branches could have a week-long survey with several surveyors.

After the Survey

After the survey has been completed and reports submitted, final accreditation decisions are made. Although surveyors give recommendations, they are not the deciding individuals. For JCAHO, accreditation is determined by a computerized aggregation system and overseen by a board. ACHC has an Accreditation Review Committee that makes the final determination, and CHAP has its Board of Review. All rely heavily on the information gathered and reported by the surveyors.

The provider will be notified of results and, if accredited, will receive a certificate. As of this year, all three accreditors give results in a narrative report.

Accreditation shows a supplier has met standards above those required to operate a business, and so not all organizations may be accredited. Although today a denied supplier can still remain in business, this will not be the case in the future. For this reason, it is important to begin now — and avoid the last-minute rush.

Jerold S. Cohen is president of Caesar Cohen, Ltd., a consulting firm specializing in accreditation preparation, compliance training, outsourcing and operations management. He has served as president/CEO of CHAP, and currently performs accreditation surveys for ACHC. He can be reached by e-mail at [email protected] or by phone at 609/364-3712.