Dealer/Provider chatted with Mary Ellen Conway, president of Capital Healthcare Group LLC, Washington, DC, about the good, the bad, and the confusing aspects of CMS’ new accreditation quality standards. Readers will remember that the standards were required by the Medicare Modernization Act for all providers who wish to bill Medicare under competitive bidding. Providers in the first 10 metropolitan statistical areas (MSAs) must be accredited in 2007. At press time, the 10 MSAs had not yet been named.

Dealer/Provider: What gaps and/or points of clarification jump out at you as you read this 14-page document?  

Conway: There is nothing in there about infection control, but you would never survey an organization and not look at their infection control standards and guidelines. There is nothing about benchmarking, health screenings, or criminal background checks. They went so minimal on this—which is good in many ways—but does that leave it open for Joe Blow’s accreditation company to open a company that surveys only on those 14 pages and not everything else? And now do you get fly-by-night accreditation? Overall, the pendulum swung. CMS was way overprescriptive, and they realized it. Now it has swung the other way, and I have a million questions. And I don’t know how we are going to pose these questions because there is no comment period.

D/P: Do these new standards address whether providers should follow state requirements?

Conway: There are American Respiratory Care Board guidelines that advise you to check if you have a state that requires you use an RT. What if you are in Virginia and you are not required to use an RT—or some other state where they don’t have RT guidelines that say to administer oxygen you must have an RT. Does that mean those do not apply to you? I think there is a lot of clarification that still needs to come. I think they went with minimal, which is great, but in the middle would have also been great. Not more standards, but more explanation.

The good news is that at first they were so overly prescriptive. For example, in the proposed regulation, under support surfaces, it said you must involve an enteral-stoma nurse. And everybody said, “Are you out of your mind? There are something like 4,000 of them in the country. How are we going to get them involved?” So, fortunately, that is gone. If I were a provider, I would look at 14 pages and say this is totally manageable. But I don’t think the accreditation organizations need to change their programs and make them tiny. That’s not right.

D/P: How will these new standards affect providers who are in the middle of accreditation, or those who have surveys scheduled soon?

Conway: A couple of weeks ago, I was working with a regional drug distributor and they are putting together a program for their members to help them with accreditation. And I talked to ACHC and JCAHO, and they said, “We are looking at a smaller version for DMEs, and we are going to try to eliminate some of these standards.” Does that mean they are going to come out with a mini version?

What about my client in Detroit who is scheduled to be surveyed on November 1? He’s got the big fat book. Do we cancel his survey and wait and see if we come out with something else? And we still don’t know what the MSAs are. Now, if Detroit is an MSA, they have to get accredited right away, and they are going to go through a lot of hoops for JCAHO accreditation for what is currently in place right now. If JCAHO skinnies this down in 2 months, that really hurts [the Detroit provider] because that is more work that he has to pay to do.

Dealer/Provider: Will new standards help reduce costs for providers? 

Conway: CMS said that reducing all of this would take care of small providers. Well, small providers are going to pay the same amount of money as before because accreditation costs are kind of fixed. They are already priced  by your size and how many offices you have, and how long your survey has to be. So to say that [CMS] came up with this reduced amount of standards to accommodate small business I think is off the mark. I think it helps everybody.

I think the shortened standards are a positive thing, but there is so much that we have to sift through by January that it is hard to know where we are quite yet. Is it really next to nothing? It can’t be.

You cannot go to an organization and not require that they have criminal background checks, but there is nothing  saying that. There is nothing in these 14 pages that says follow all health care guidelines for the state. It leaves so many questions. It leaves a lot of stuff for us to clarify, and maybe we will in the next few weeks.

In the previous release 2 months ago, CMS said we don’t think providers should have to buy manuals and pay consultants. I said I don’t mind if they don’t pay consultants, but no one ever had to. However, if you are a small operation and you need help, then you hire someone to help you. And nobody requires that you buy manuals, but if you want to buy a policy and procedures book, that is a huge savings of your time not to have to develop those things.