Transcript The ABC’s of Competitive Bidding Preparation
Accreditation and Quality Standards
Accreditation Deadline
CMS has announced that all providers having the intention to bill Part B Medicare must be accredited by
September 30, 2009
.
Failure to achieve accredited status by this date will result in revocation of billing privileges by the National Supplier Clearinghouse.
Providers must be accredited by one of the ten deemed accrediting organizations.
Accreditation for New Suppliers
Providers entering the marketplace after September 30, 2009 will need to immediately begin the accreditation process
Recognized National Accreditation Organizations for DMEPOS
Joint Commission on Accreditation of Healthcare Organizations Community Health Accreditation Program Healthcare Quality Association on Accreditation National Board of Accreditation for Orthotic Suppliers/Board of Certification in Pedorthics (merged) Accreditation Commission for Healthcare Inc.
Board for Orthotist/Prosthetist Certification National Association of Boards of Pharmacy Commission on Accreditation of Rehabilitation Facilities American Board for Certification in Orthotics and Prosthetics Inc.
The Compliance Team Inc.
Accreditation Requirement
Regardless of the “accreditation deadline”, all supplier standards are still in effect. CMS directly and through its contractor, the National Supplier Clearinghouse (NSC), will still enforce and interpret all standards.
CMS has requested accreditation organizations to include a plan that outlines their methodology to reduce accreditation fees for small or multiple location suppliers.
Four New Supplier Standards!
The following items were added as Medicare suppliers standards in the Federal Register notice dated August 18, 2006. However, CMS has not set a deadline for DMEPOS suppliers outside the first 10 CBAs to become accredited in order to retain/obtain a billing number. Therefore, at this, suppliers needed to comply with only 21 standards to enroll in the Medicare program.
The Standards…
(24) All DMEPOS supplier locations, whether owned or subcontracted, must meet the DMEPOS quality standards and be separately accredited in order to bill Medicare. An accredited supplier may be denied enrollment or their enrollment may be revoked, if CMS determines that they are not in compliance with the DMEPOS quality standards.
(25) All DMEPOS suppliers must disclose upon enrollment all products and services, including the addition of new product lines for which they are seeking accreditation. If a new product line is added after enrollment, the DMEPOS supplier will be responsible for notifying the accrediting body of the new product so that the DMEPOS supplier can be re-surveyed and accredited for these new products.
The Standards…
(22) All suppliers of DMEPOS and other items and services must be accredited by a CMS-approved accreditation organization in order to receive and retain a supplier billing number. The accreditation must indicate the specific products and services for which the supplier is accredited in order for the supplier to receive payment for those specific products and services (23) All DMEPOS suppliers must notify their accreditation organization when a new DMEPOS location is opened. The accreditation organization may accredit the new supplier location for 3 months after it is operational without requiring a new site visit.
Accreditation for Competitive Bidding
In order to participate in the Medicare DMEPOS Competitive Bidding Program, suppliers must meet quality standards and be accredited by a CMS-approved Deemed Accreditation Organization.
The accreditation deadline for Round Two of competitive bidding has not yet been released.
Suppliers must be accredited or be pending accreditation to submit a bid. CMS cannot accept a bid from any supplier that is not accredited or that has not applied for accreditation.
Frequently Asked Questions
Is DMEPOS accreditation mandatory? Yes, for Medicare. The MMA of 2003 mandates a final rule requiring accreditation and competitive bidding for entities providing DMEPOS, diabetes, and Part B supplies and services.
Must I obtain accreditation to acquire or retain my Medicare Part B supplier billing number? Yes.
What happens if my HME does not obtain accreditation? Your facility will not be able to competitively bid for DMEPOS products and will not be eligible for reimbursement by Medicare for DMEPOS supplies and services.
Will accrediting organizations prioritize facilities in the initials MSAs? Yes.
When is the last date that my company is required to be accredited? CMS has not yet announced the accreditation deadline for Round Two CBAs. The deadline for all Part B providers has been set for
September 30, 2009
.
Do I need to buy a manual in order to become accredited? A manual, per se, is not required by the regulations. However, accrediting organizations will require all supporting documentation requested with the application to be submitted. Manuals may be appropriate for facilities to ensure the HME is in compliance with the CMS Quality Standards.
Quality Standards and Accreditation
♦ Contract suppliers must
meet quality standards
specified by the Secretary under section /1834(a)(20) of the Act ♦ Quality standards applied by recognized independent accreditation organizations designated by the Secretary ♦ Bidding suppliers must be
accredited
approved accreditation organization by a CMS ♦ Quality Standards
will
just those in bid areas apply to ALL suppliers, not
Quality Standards
In August of 2006 CMS released the final supplier quality standards--which HME providers must meet not only to participate in the bid but also to do any Part B business More than 5,600 stakeholders commented, with the most common complaint that they were "too prescriptive. Agency officials agreed.
CMS performed “significant revisions to reduce burden on small suppliers and ensure quality services for Medicare beneficiaries.” The final standards reflect more general good business practices and product specific services. CMS suggests that many suppliers already comply.
An
Executive Summary
with excellent quality standard compliance tips is available on vgm.com.
Actual copies of the final standards are available on the CMS website and on vgm.com.
Validation Surveys
CMS may conduct validation surveys of suppliers to validate the accreditation organization’s survey process.
A supplier selected for a validation survey must authorize the survey to take place and allow a CMS survey team to monitor the correction of any deficiencies found through the validation survey.
If a deficiency is discovered by the validation survey, CMS may revoke the supplier’s billing number or require the accreditation organization to perform a full accreditation survey at the accreditation organization’s expense.
If a validation survey results in a finding that the supplier is out of compliance with one or more Medicare quality standards, the supplier’s billing number may be revoked.
A supplier who fails to cooperate with the validation survey will be deemed as no longer meeting the Medicare quality standards and its billing number may be revoked.
A summary of the quality standards follows next!
Final Supplier Quality Standards
First Section: Business Services ♦ Administration ♦ Financial Management ♦ Human Resource Management ♦ Consumer Services ♦ Performance Management ♦ Product Safety ♦ Information Management
Final Supplier Quality Standards
Second Section: General Product Specific Service Standards Preparation – Intake – Beneficiary Record Delivery and Set-Up Training/Instruction to Beneficiary and Caregiver Follow-up
Final Supplier Quality Standards
Appendix A- C
A:
Respiratory Equipment, Supplies & Services ♦ Oxygen concentrators, reservoirs, high pressure cylinders, oxygen accessories and supplies, oxygen conserving devices ♦ ♦ ♦ ♦ ♦ Home invasive mechanical ventilators CPAP Devices Respiratory Assist Devices IPPPB Devices Nebulizers
Final Supplier Quality Standards
Appendix A- C B: Manual Wheelchairs, Power Mobility Devices, Complex Rehab and Assistive Technology Key Issues in Complex Rehab and Assistive Technology: ♦ ♦ ♦ ♦ Check items listed Employ at least one qualified RTS per location Provide appropriate equipment for trial Provide private, clean and safe rooms appropriate for fitting and evaluation ♦ Maintain a repair shop located in the facility
Final Supplier Quality Standards
Appendix A- C C: Custom Fabricated, Custom Fitted, Custom-made Orthotics, Prosthetic Devices, Somatic, Ocular and Facial Prosthetics and Therapeutic Shoes and Inserts Not off-the-shelf items
Policy and Procedure Manual
♦ Must meet the needs and requirements of the accreditation provider you select ♦ Not worth trying to create on your own at this point
Review Patient Paperwork…
♦ Consent for Treatment/Services ♦ AOB ♦ Third Party Review ♦ HIPAA Information ♦ Disaster/Emergency Preparedness ♦ How to Reach the Office (Hours)
Educational Materials & Competency Program: ♦ Many of the requirements of the standards speak directly to the educational materials you provide to your patients ♦ Competency Program - Review the requirements of your accreditor and be sure you meet them ♦ Generally only technical staff are required to have competency evaluated ♦ Can be written (testing) but must be observed for technical staff
Performance Management
1.
2.
3.
4.
5.
Beneficiary satisfaction surveys Patient complaint log After hours (on call) log to prove timeliness of response to questions, problems and concerns Log that documents frequency of billing and/or coding errors Log documenting adverse events (as defined by your P & P manual)
Most accrediting organizations require at least three months of surveys collected and summarized with plans for improvement or you will have to provide written follow-up and possible a re-visit
Some Preparation Steps
Review all licensing requirements, including business, DME, pharmacy, and other licenses..
Become familiar with all applicable laws and rules.
Be sure to post all documents that are required to be posted (e.g., Family Leave Act, Equal Employment Opportunity Act, OHSA, Job Safety & Health Protection Act, Minimum Wage laws, etc.)
Employee Matters
Screen employees against the OIG exclusion database regularly, and document the results of the screening.
Have policies on employment issues, such as sexual harassment and employee grievances.
An employee handbook is highly recommended.
Have written job descriptions and document employee credentials.
For licensed staff, include documentation that the person is in compliance with state continuing education requirements.
Other Matters
Hazardous Materials - Have an MSDS file for all hazardous materials used (e.g., germicides, toner, bleach, battery acid, oxygen, etc.).
Infection control Equipment setup and delivery Emergency preparedness Equipment & vehicle maintenance and repairs Maintain an equipment maintenance log.
Cleanliness Matters!!
Make sure office space, warehouses, supplies, delivery vans, etc., are clean and organized.
Mark clean and dirty areas.
Make sure corporate documents (e.g., Articles of Incorporation, minutes, organization charts, etc.) are in order.
National Provider Identifier
CMS has stated the beginning March 1, 2008 all Medicare claims must include a National Provider Identifier (NPI) – The NPI may be by itself or in conjunction with a legacy identifier beginning at this time Starting May 23, 2008, CMS will only accept NPIs
Educational Teleconferences
Beginning January 22, 2008 CMS will offer a series of educational teleconferences Medlearn Matters and other educational resources will become available to help providers become accredited