ATLANTA--After announcing Sept. 30, 2009, as the deadline by which all DMEPOS providers must be accredited, CMS officials at an Open Door Forum Dec. 19 refused to give out information on additional dates. But the accreditation deadlines for new suppliers were revealed just two days later in a list serv for pharmacists--and the dates are raising questions.
According to the list-serv notice, sent Dec. 21 and confirmed by HomeCare Monday through CMS' Office of the Administrator, DMEPOS suppliers who enroll with the National Supplier Clearinghouse (NSC) before March 1, 2008, will have until Jan. 1, 2009, to obtain accreditation. On or after March 1, 2008, those seeking NSC enrollment must be accredited prior to submitting an application.
The latter stipulation--requiring that providers be accredited before submitting an application to receive an NSC number--has raised some issues.
"[Becoming accredited] includes gathering data on your Medicare beneficiaries, but how can you gather data on billing and collections and beneficiary satisfaction if you don't have any beneficiaries?" questioned industry consultant Mary Ellen Conway, president of Capital Healthcare Group, Bethesda, Md. In addition, she pointed out, "You can't become a Medicaid provider until you have acquired your Medicare number, so no Medicaid patients, either."
Mary Nicholas, executive director of the Waterloo, Iowa-based HealthCare Quality Association on Accreditation--one of 10 accrediting organizations approved by CMS--said she is awaiting clarification from the agency on exactly how getting accredited prior to receiving an NSC number would work, but she fears such a process might have a chilling effect on HME.
"I am concerned for the growth of the industry," Nicholas said.
While the requirements for new suppliers have generated new questions, the "drop-dead" accreditation date of Sept. 30, 2009, has rekindled old concerns. The deadline may be 21 months away, but accreditors and consultants are already warning HME providers not to drag their feet. Any delay could cause last-minute applicants to be left out in the cold, they said, especially with the second round of competitive bidding looming.
Although she is relieved CMS has allowed a "manageable" amount of time for existing providers to complete the accreditation process, "you may not have as much time as you think," Conway cautioned. "Accreditation generally takes between four and six months, and part of that has to include time for the unannounced survey, which can take another 45 to 90 days.
"Plus," she continued, "if CMS announces the next 70 MSAs anytime soon, there will certainly be a deadline in those MSAs in order to bid, and that deadline will come well before the Sept. 30, 2009, deadline."
HQAA's Nicholas agreed. "If the past year was any indication of the 'norm' or typical behavior of the [HME] population, then there will be a last-minute rush for accreditation. There were people calling us in July trying to make the August deadline [for first-round bidders].
"Please remember you must allow yourself enough time to complete the accreditation journey," she advised providers.
"Many companies have been dragging their feet to see when the deadline was going to be," Conway said. "Now they have no excuse."
According to a recent survey of HomeCare readers, 43 percent of the HME providers polled (before the CMS announcement) remain unaccredited. Of those, 29 percent said they planned to apply in 2008, another 5 percent in 2009, and another 16 percent "when CMS requires it for all providers."
The number of unaccredited providers coupled with other factors could create something of a scramble, accreditors said.
Unaccredited providers in CMS' anti-fraud demonstration areas in south Florida and southern California must gain accreditation within 120 days of notice that they must reenroll in the Medicare program. (See Homecare Monday, Nov. 5.) And providers in all of the country's big cities should begin the process immediately with CMS expected to ramp up Round Two of competitive bidding at any time, accreditors said.
"If you're living in one of the nation's top 100 biggest cities and you weren't included in the first round, you can pretty much guarantee that you'll be included in this round," said Sandra Canally, president of The Compliance Team, Spring House, Pa. "Don't keep waiting for CMS to make the announcement. If you're in Atlanta, you're going to be part of it. If you're in L.A., it's coming. So many people still have their heads in the sand thinking that this is going to go away, and it's not."
According to Canally, HME inquiries have increased since the CMS deadline announcement, but she worries many of the industry's providers do not understand the gravity of the timetable.
"They don't understand that this is so far-reaching," she said. "Accreditation affects podiatrists, physical therapists, occupational therapists, physicians--even people who provide corrective lenses. Anybody who bills anything DME-related to Part B comes under this mandate. So when they set the deadline of Sept. 30, 2009, we're not talking about just providers within the DME industry who need to become accredited.
"The 10 accrediting bodies are going to have to look at up to 100,000 providers by the deadline date," Canally said.
Despite the potential for an accreditation crunch, Conway said, "if you apply right now, you should have plenty of time. But the more you delay, the more problems you may have."
A list of the 10 CMS-approved accreditation organizations can be
viewed online at
www.cms.hhs.gov.