Mary Ellen Conway

Unless you have been living under a rock, you know that the cause of much commotion in the DME industry is the requirement of mandatory accreditation by a CMS-“approved” organization by 2007. The question for most is: Who is approved?

The Medicare Modernization Act of 2003 (MMA) requires that all DME and orthotic and prosthetic providers with a Medicare supplier number become accredited. Estimates are that there are more than 30,000 supplier numbers that do not report any type of accreditation. For new providers, the initial accreditation process takes anywhere from 4 to 9 months. At that rate, the market is going to be saturated with providers seeking accreditation by the end of this year. But who do you choose? Who is approved? Right now, the answer is no one.

In March, CMS released the guidelines of how it was going to approve accreditation organizations. The regulations can be found in the Code of Federal Regulations, Title 12, Volume 1, revised in January 2003 at 42CFR488.1, or Part 488. Part 488 is 12 pages replete with regulations and requirements that an accreditation organization must meet to become “approved.” This is known as becoming a deemed status provider.

These regulations require that accrediting organizations go through a lengthy process. They will submit a tremendous amount of information to CMS for review to determine if they can be awarded deemed status and become an “approved” accreditation provider for purposes of compliance with these regulations. The requirements are voluminous and include such straightforward items as the organization be a nonprofit, provide the specifics of their accreditation program, and explain how their accreditation is awarded and denied. Other requirements are more complex, such as providing a description of the organization’s data management and analysis system. As the president of one accreditation group told me recently, “It is a daunting process to become a deemed status provider.”

Additionally, as part of the application process, CMS will visit the accrediting organization on site to review all of the information supplied with the application. This will include a review of the physical office space, an examination of policies and protocols, and a review of the training and education of field survey staff. This application is an enormous process and one that may take months to successfully complete. The regulations also state that these deemed status accrediting organizations must reapply for continuing approval every 6 years.

Once an organization has been approved as a deemed status provider, CMS will conduct validation surveys. This means that a certain percentage of all of the providers accredited by the organization will have an on-site survey by CMS to validate that the information provided by the accrediting organization is authentic. This will be the case for all approved DME accreditation providers.

Of the current accrediting organizations, JCAHO and CHAP are deemed status providers in home care and hospice. ACHC has applied for both as well. However, each of these organizations will now have to apply for approval as a deemed provider for DME.

If that is the case with “approved,” what about “recognized?” Is that some kind of distinction? Well, that depends on who you ask. Do you recognize the names of organizations? Does that hold a value for you? Marketing gurus tell us that there is tremendous value in name recognition. Is there such a thing as being a “recognized” DME accreditation provider? The answer is that it depends on what the recognition actually is.

Can you pursue accreditation with an “approved” accreditation provider right now? No, not yet. Hopefully, CMS will move swiftly and we will have those answers by the end of this year.

Mary Ellen Conway is president of Capital Healthcare Group LLC, a health care consulting group in Washington, DC. She can be reached through her Web site: www.capitalhealthcaregroup.com.