Transcript Medicare Part B Reimbursement
CMS Accreditation Update - The Latest from the MSAs: What Do You Need to Do and When Do You Need to Be Ready?
Tuesday, October 2, 2007 MedTrade
.
Mary Ellen Conway President
Overview
• What is the Accreditation Requirement?
• First 10 MSA’s, Next 70 • When do YOU Need to be Ready?
• Current Important Legislative Activity • “Inconspicuous Items” • Report from the First 10 CBA’s 2
Overview Continued
• How Do You Get Started?
• Tips on Choosing Your Accreditor – Issues with fees/costs • The Current Ten Recognized Accreditation Providers • Models/Formats • Video Examples • Main Reasons Organizations Fail • How Long Does It Take?
• Ten Things You Can Do Now to be Ready 3
Common Acronyms
CBA Competitive Bid Area CBIC CMS Competitive Bidding Implementation Contractor Center for Medicare Medicaid Services DME Durable Medical Equipment DMEPOS Durable Medical Equipment, Prosthetics, Orthotics and Supplies HME MMA ’03 MSA Home Medical Equipment Medicare Modernization Act of ’03 Metropolitan Statistical Area 4
What is the Accreditation Requirement?
• The Medicare Modernization Act of 2003 (MMA ’03) states that
ALL DME
Providers billing Medicare for identified Part B products must be accredited by 2007--- this will be enforced initially through the Competitive Bidding Requirement • There are between 117,000 and 150,000 Medicare Part B supplier numbers • This applies to DME’s as well as pharmacies billing for identified items 5
The “Dominos”
• CMS is enforcing the law that requires competitive bidding in 2007 (Slated to begin July 2008) • Only accredited organizations can be awarded a bid • Accreditation must be by recognized accreditors • Provider must comply with Final Quality Standards (Released 8-14-06) 6
Why is this happening?
• High profile fraud and abuse cases • New price list alone will not solve 7
Competitive Bidding Timeline
• Bidding opened May 15, 2007 • Bidding closed September 26, 2007 • Competitive bidding contracts will be awarded for 3 years (with the exception of mail order diabetic supplies), starting July 1, 2008 in the identified 10 CBA’s and in a additional 70 (for a total of 80) to begin July 1, 2009 • See website www.dmecometitivebid.com
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The First 10 CBA’s
Charlotte-Gastonia-Concord: NC-SC Cincinnati-Middletown, OH-KY-IN Cleveland-Elyria-Mentor, OH Dallas-FT Worth-Arlington, TX Kansas City, KS-MO Miami, Ft Lauderdale, Miami Beach, FL Riverside, San Bernadino, Ontario, CA Orlando, Kissimmee, FL Pittsburgh, PA San Juan, Caguas, Guaynabo, Puerto Rico 9
Next 80 Largest MSA’s
Los Angeles Washington, DC Phoenix Nassua/Suffolk Portland, OR Boston Columbus, OH Salk Lake City Providence. RI Middlesex/Somerset Jacksonville Philadelphia, PA New York St Louis, MO/IL Seattle Oakland, CA Ft Worth, TX Indianapolis Milwaukee Greensboro, NC Raleigh/Durham Memphis Rochester, NY San Francisco, CA Chicago Richmond, VA Houston Denver Las Vegas San Antonio Bergen, NJ Austin Hartford W Palm/Boca Grand Rapids Tampa San Diego Louisville Atlanta Newark, NJ San Jose, CA Virginia Beach New Orleans Nashville Buffalo Monmouth Fresno Detroit 10
Next 80 Largest MSA’s Con’t
Oklahoma City Albany Syracuse Knoxville Allentown, PA Jersey City Greenville, SC Tucson Omaha El Paso Harrisburg Baton Rouge Little Rock Charleston Ann Arbor New Haven, CT McAllen/Edinburg, TX Dayton, OH Tulsa Albuquerque Bakersfield Scranton Youngstown, OH Honolulu Ventura, CA Akron Gary, IN Toledo, OH Springfield, MA Stockton, CA Mobile, AL Wichita Columbia, SC Sarasota/Bradenton 11
The CBA (Competitive Bid Area)
Can be multiple MSA’s
– Applies to defined Zip Codes where the
beneficiary resides
, not where the provider is located – Check CBIC website for service area zip codes- can be an enormous service area 12
When Do You Need to Be Ready?
• If you provide any of the identified products or services to Medicare beneficiaries in any of the defined areas and wish to continue, you will be required to bid.
• In order to bid, you will need to be accredited • If you do not bid, or do not win the bid, you are excluded for three years- you CAN NOT bill from an office in another area • All others may be required to be accredited (whether or not there is Competitive Bidding in your service area) as early as
2009 April 1,
“Everyone else after that” 13
What if You Provide Products and Services in Rural Areas Only?
• You may never have to participate in Competitive Bidding • You will get a rate adjustment as CMS will begin to reimburse providers the rates paid in the closest MSA’s • You must be accredited by some finite date 14
Final Product Categories
1.
2.
3.
Oxygen Supplies and Equipment Standard Power Wheelchairs, Scooters and Related Accessories Complex Rehab Power Chairs and Related Accessories Mail Order Diabetic Supplies 4.
5.
6.
Enteral Nutrients, Equipment and Supplies CPAP, RAD’s and Related Supplies and Accessories Hospital Beds and Related Accessories 7.
8.
Negative Pressure Wound Therapy Pumps and Related Supplies and Accessories 9.
Walkers and Related Accessories 10. Support Surfaces (Groups 2 mattresses and overlays) in Miami and San Juan only 15
Product Selection
• CMS selected products for CB based on: – High cost – High-volume – Greatest potential for savings 16
Legislative Activity
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What’s the update from the First 10 CBA’s?
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Deadlines were VERY tight
• Many suppliers had their applications and funds returned at the end of June/beginning of July (before the extension was announced) from accreditors • For many who were surveyed in time, they had extensive amounts of follow-up that needed to be done due to incomplete work. This often included re-visits • All has to be complete by October 31st 19
Multiple Bidding Issues
• Geographic area in each was VERY extensive • Capacity issues- wait to be seen who is awarded bids 20
The Next 70?
• Complaints in Florida about 20 minute accreditation surveys • Results of validation surveys?
– PAOC Meeting scheduled for October 11, Baltimore, MD • CMS announced that they are ready for the next 70 CBA’s- could be before the first round contracts begin – Herb Kuhn, AAHC Legislative Conference, June 6 21
How Do I Get Started???
Must Have Performance Management 1. Beneficiary satisfaction surveys 2. Patient complaint log 3. After hours (on call) log
timeliness of response to questions, problems and concerns to prove
4. Log
that documents
frequency of billing and/or coding errors 5. Log
documenting
adverse events
defined by your P & P manual) (as 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 23
Performance Improvement Examples are Everywhere…
Where do you see them?
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Tips to Use in Choosing Your Accreditor
• CMS is not your only payer!
– Payer or state licensure requirements to be accredited ex: Anthem BC, State of Florida, Oklahoma Medicaid • What is the accreditor’s schedule and what are the requirements for in-between? – ex: Triennial and or annual updates • Fees paid vs. administrative costs • Other services (infusion, home health) • Process (electronic vs. paper) • Interview/discussions with accrediting organization— your perceptions • Your peer’s experience 27
The Current Ten Recognized Accreditors
Not every organization is an option for you
Comparing “Apples-to-Apples”
Product Category Definitions
DME Limited
Mobility Aids: Manual W/C, Cane, Walker, Crutches, Stationary Commode Chairs, Wound Care and Ostomy Supplies Urological Supplies: Bedpans, Urinals
DME includes Limited and
- Manual and Electric Beds, Traction Equipment
Medical Supplies-
Diabetic Supplies, Enteral Products (Non-home visit items)
Respiratory-
Home medical equipment and supplies covered include respiratory equipment and supplies, oxygen, concentrators, reservoirs, conserving devices, cylinders and oxygen accessories and supplies, home invasive mechanical ventilators, respiratory assist devices, continuous and intermittent positive pressure breathing devices,
Rehabilitation-
nebulizers Power Mobility devices including complex Rehab and Assistive Technology
Orthotics and Prosthetics-
Custom fabricated, custom fitted, custom-made orthotics, prosthetic devices, somatic, ocular and facial prosthetics, therapeutic shoes, braces and artificial limbs 29
Accreditation Commission for Healthcare (ACHC)
www.achc.org
DME- All Equipment Medical Suppliers (Pharmacies) Respiratory Rehabilitation Orthotics and Prosthetics 30
American Board of Certification for Orthotics and Prosthetics (ABC of O&P)
www.abcop.org
Orthotics and Prosthetics DME Limited- Wound Care/Incontinence, Mobility Aids
only if in conjunction with O&P
Merged with the Board for Certification in Pedorthics (www.cpeds.org) 31
Board of Orthotic/Prosthetist Certification (BOC)
www.bocusa.org
DME- All Equipment Medical Suppliers (Pharmacies) Respiratory Orthotics and Prosthetics 32
Commission on Accreditation of Rehabilitation Facilities (CARF)
www.carf.org
Rehabilitation Orthotics and Prosthetics 33
Community Health Accreditation Program (CHAP)
www.chapinc.org
DME- All Equipment Medical Suppliers (Pharmacies) Respiratory Rehabilitation Orthotics and Prosthetics 34
The Compliance Team
www.exemplaryprovider.com
DME- All Equipment Medical Suppliers (Pharmacies) Respiratory Rehabilitation Orthotics and Prosthetics 35
Healthcare Quality Association on Accreditation (HQAA)
www.hqaa.org
DME- All Equipment Medical Suppliers (Pharmacies) Respiratory Rehabilitation Orthotics and Prosthetics 36
Joint Commission (JCAHO)
www.jcaho.org
DME- All Equipment Medical Suppliers (Pharmacies) Respiratory Rehabilitation Orthotics and Prosthetics 37
National Association of Boards of Pharmacy (NABP)
www.nabp.net
DME Limited- Wound Care/Incontinence, Mobility Aids Medical Suppliers (Pharmacies) 38
National Board of Accreditation for Orthotic Suppliers (NBAOS)
www.nbaos.org
Orthotics and Prosthetics 39
Models/Formats
Models/Format of Programs • Additionally – Paper Based vs Electronic 40
Video Examples
• Anxiety about the Surveyor • Home Visit 41
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Home Visits
GO OUT AND SEE WHAT’S HAPPENING!!!
Surveyors will interview patients, asking how they were oriented, how to reach the office, how the services has been, any problems… 43
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Main Reasons Organization Fail
• Lack of Preparedness • Few Staff Aware of Process/Requirements • Lack of Focus and Follow-through • Main items: – Physician Orders – Infection Control – Incomplete HR Files 45
How Long Does It Take?
Generally
at least
4 – 6 months from start to completion • Do you have everything you need?
– Policies and Procedures, Educational Materials, etc.
– How long will it take for you to get these in place?
• Once you gather your information, how long will it take for you to coordinate and submit your materials?
– Average is 2 – 3 months • When you notify your accreditation company that you are ready, how long until your survey?
– Schedules are usually 45 – 60 days in advance-Surveys must be un-announced within a window of time that you are ready 46
10 Things You Can Do
1.
Download and become
VERY
comfortable with the final quality standards---read them carefully 2.
3. Review and talk to your payers to make an informed decision as you
choose your accreditation provider right away
Send for your accreditor’s standards
ASAP
4. Review and update your P&P (or
BUY
one!) 5.
www.vgmeducation.com/shop www.accreditationresources.com
Identify your team(s)--- review the standards by team and identify what you need to do 47
10 Things You can Do
6. Educate the staff NOW- practice discussions 7. Create/review your PI program required logs
ASAP-- NOW –
begin to collect patient satisfaction data and implement the Gather at least 3 mos of data before notifying accreditor that you are ready 8. Review all patient education materials to see what you will need to update/change so that they match the final standards 9. Review physical plant, warehouse, vehicles 10. Perform a Mock Survey- make corrections
Notify your provider that you’re ready!
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Stay Tuned!
• Watch for updates in the media on a weekly basis • Release of the next 70 CBA’s (can be multiple MSA’s) • Conferences held by the CBIC to instruct beneficiaries • Pricing for items for bid in the first CBA’s 49
The Most Effective Way to Survive and Thrive in Your Business is to
Be Prepared
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Your Questions ???
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Thank You!
Mary Ellen Conway President Capital Healthcare Group, LLC Bethesda, MD 301-896-0193 www.capitalhealthcaregroup.com
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