CMS recently posted the display copy of its final rule for DMEPOS accreditation as part of its Medicare Modernization Act (MMA) rollout. These directives did not include the final quality standards for DMEPOS (although standards did come out in mid August), nor did they identify the first 10 metropolitan statistical areas (MSAs) where the MMA is to be implemented in 2007.  At press time, here are seven things that we know:  

1) All providers billing Medicare Part B for DMEPOS items and services are mandated to meet the quality standards and become accredited to maintain a supplier number and continue to bill Medicare.

2) Providers in the first series of MSAs will need to be accredited in early 2007. Providers in the next set of MSAs must have their accreditation validated and completed by the winter of 2007.

3) The nationally recognized accrediting organizations initially identified by CMS in 2004 were: The American Board for Certification in Orthotics and Prosthetics (ABC/BOC), Accreditation Commission for Health Care Inc (ACHC), Community Health Accreditation Program Inc (CHAP), Compliance Team Inc, and Joint Commission on Accreditation of Healthcare Organizations (JCAHO).

4) All of the accrediting organizations will need to perform unannounced on-site evaluations.

5) Accrediting organizations will now be required to evaluate ALL provider locations. (Statistically valid samplings of multisite organizations will no longer suffice.)

6) Accrediting organizations will need to evaluate and accredit according to specific product lines (such as wheelchairs, walkers, and canes). If providers add supply lines after being accredited, they would have to be reaccredited for those new items.

7) CMS still needs to address the “grandfathering” of current accredited providers to remove the uncertainties that surround choosing an accrediting body, as well as for the accrediting organizations to better prepare for the looming logjam that surely lies ahead.

In the current display copy of the Final Ruling, CMS said this about a grandfathering clause: “We recognize the need to provide an alternative mechanism to accommodate currently accredited suppliers. As stated in the proposed rule, we will provide further guidance on a process to accredit DMEPOS suppliers that currently maintain an accreditation with an accreditation organization.”

The Compliance Team’s recommendations to CMS concerning grandfathering are as follows:

• Providers holding a valid “Certificate of Accreditation” from any of the nationally recognized DMEPOS accrediting bodies should be permitted to continue its participation in Medicare until January 31, 2009. After that date, all providers must show evidence that they maintain a valid accreditation from an approved DMEPOS accrediting body.

• Providers not accredited at the start of the MMA (January 1, 2007), but who are enrolled in one of the CMS-identified accreditation programs will be permitted to continue their participation in Medicare programs for a “grace” period of 1 year from the time of the provider’s enrollment in such a program. Upon the end of its 1-year grace period, said providers must produce a valid Certificate of Accreditation or risk losing Part B eligibility.

• Starting February 1, 2009, all providers who wish to participate in Medicare programs must show evidence that they hold a valid Certifi-cate of Accreditation from a CMS-approved DMEPOS accrediting body.

No doubt what lies ahead is going to be difficult on us all. As a small business owner and a passionate advocate for accreditation simplification, I also do not relish the idea of being regulated by a large government bureaucracy. However, given the realities of the MMA, we will do whatever needs to be done to stay in the game so we can continue to help providers achieve health care delivery excellence. Likewise, I am certain that the small businesses that form the foundation of the DMEPOS industry will find a way to move forward despite the uncertainties that confront us. After all, at the end of the day, your patients need you.

Sandra Canally, RN, is president of The Compliance Team Inc, Spring House, Pa. She can be reached via e-mail: cteam@mac.com.