Subcontractor Accreditation Guidance Out ‘Soon’

ATLANTA—If you thought you missed a clarification
concerning accreditation guidelines for subcontractors, think
again. Providers and others had hoped for additional information at
a Sept. 9 Open Door Forum, but CMS’ Sandra Bastinelli, in
charge of the agency’s accreditation program, said only that
guidance would be coming “soon.”
 
“CMS has still not issued their written clarification,”
confirmed Cara Bachenheimer, senior vice president of government
relations for Invacare, Elyria, Ohio. “This issue is still
very confusing to many, and there is lots of misinformation out
there.”
According to Mary Ellen Conway, much of the confusion stems from
the definition of what constitutes a subcontractor.
 

At a June meeting of the Program Advisory and
Oversight Committee, documents identified the Medicare services a
subcontractor can perform as the purchase of inventory, delivery
and instruction on use of Medicare-covered items and repair of
rented equipment.

“If you interpret it broadly, for example, a subcontractor
could be anyone who repairs or provides maintenance on
equipment,” said Conway, president of Capital Healthcare
Group, Bethesda, Md. “CMS has to clarify this, because you
may be including all the manufacturers.”
 
Conway doubts this is CMS’ intent, however, and instead
thinks the agency will likely focus more attention on
subcontractors who instruct or deliver to Medicare
beneficiaries.
 
“I think they need to keep it fair,” said Conway.
“If they are requiring people who instruct the customer to be
accredited, then they have to make sure that anyone who is doing
that on behalf of an accredited provider meets those accreditation
guidelines.” 
 
Will subcontractors be subject to the same accreditation deadlines?
Again, it is not clear.
 
If so, said Conway, that could be tough. After all, accreditation
organizations are already working feverishly to meet the Oct. 1
accreditation deadline for all DMEPOS providers. Will those
accreditors now have to ensure that subcontractors are accredited
as well?
 
“Subcontractors needed to have their own deadline and their
own timeline,” Conway believes. “If they announced the
definition of who a subcontractor could be this summer, then they
should have given the subcontractors a deadline.”