We know Medicare requires accreditation for bidding HME suppliers to continue providing products to Medicare beneficiaries within the 10 competitive bidding cities. The grace period for attaining accreditation is tight: the DMEPOS provider must be accredited by August 31, 2007, 2 months after the bids must be completed and submitted.

The organizations named by Medicare as "recognized" for accrediting HME providers are:

• Healthcare Quality Association on Accreditation (HQAA) (www.hqaa.org)
• Board for Orthotist/Prosthetist Certification (BOC) (www.bocusa.org)
• The National Association of Boards of Pharmacy (NABP) (www.nabp.net)
• The Compliance Team Inc (www.exemplaryprovider.com)
• The Joint Commission (JCAHO) (www.jointcommission.org)
• Accreditation Commission for Health Care (ACHC) (www.achc.org)
• Community Health Accreditation Program (CHAP) (www.chapinc.org)

Three other organizations were also named, but they are authorized to accredit only orthotic providers or rehabilitation facilities. Those are: National Board of Accreditation for Orthotic Suppliers; American Board for Certification in Orthotics and Prosthetics; and CARF (rehab facilities). These organizations are not authorized to accredit DME suppliers.

It is important to be aware of the full range of options because a pharmacy-based HME provider will find the National Association of Boards of Pharmacy (NABP) accreditation to be less expensive and complicated than the more well-known choices. Another frequently overlooked option is the Board for Orthotist/Prosthetist Certification (BOC). This organization can accredit DME providers even when they do not provide orthotics or prosthetics. Again, the BOC version of accreditation standards is simpler and less expensive than the big three.

Seriously consider these two options if you are looking to get accredited only for Medicare purposes. To become a participating provider with payors like Blue Cross/Blue Shield, or other managed care insurers, contact the contract representatives at the insurer to find out which accreditation organizations meet their criteria, because their list is much shorter than Medicare's.

WHAT IF YOU ARE NOT IN AN MSA?

First—lucky you. However, don't think you can stop thinking about accreditation for a few years. Our industry has distributed the supplier standards for at least a decade—currently a list of 21 requirements for the HME provider that bills for products provided to Medicare beneficiaries. In August 2006, CMS released the Quality Standards. The link to download these standards is: www.cms.hhs.gov/CompetitiveAcqforDMEPOS/04_new_quality_standards.asp

Vianna Zimbel, RCP

CMS states on its Web site: Suppliers must comply with the quality standards to furnish any DME, prosthetic device, prosthetic, or orthotic item or service for which Part B makes payment, and also to receive or retain a provider or supplier billing number used to submit claims for reimbursement for any such item or service for which payment can be made by Medicare. No matter where your company is located, the next time you see a Medicare representative, that person will be looking for activities that support these extensive standards.

Although we are now down to 14 pages from the original draft of several hundred, compliance with these standards should be a priority at your company.

WHAT'S IN THE CMS QUALITY STANDARDS?

If you are not accredited, these quality standards will push you to develop a policy manual that addresses administration, financial management, human resources, and how you provide equipment and services, handle complaints, collect information on the performance of your company (performance management), and more. If your company is already accredited, you meet or exceed most of the CMS Quality Standards. However, be sure to:

1. Modify your customer satisfaction survey to include a question for beneficiaries asking them about how your company's business practices impact their access to products and services. This may seem like an odd question, but the thought behind this is linked with competitive bidding and the criticism that by having fewer suppliers and lower reimbursement, beneficiaries will lose or have limited access to products they need. They want us to ask the question, but how to pose it to our customers is a challenge. However, before you reprint 1,000 postcards, take a moment to convene your staff and ensure that any specific questions required by CMS and your accreditation organization are on the card.
2. Include "billing and coding errors" in your performance improvement data collection and aggregation process. Specifically, CMS wants "frequency of billing and coding errors (number of Medicare claims denied, errors the supplier finds in its own records after it has been notified of a claims denial)." CMS wants us to collect data on this topic, to present and trend it in our performance improvement reports.
3. Take a look at your policies on complaint reporting. CMS imposes strict time frames for responding to beneficiary complaints. Within 5 calendar days of receiving a beneficiary's complaint, you must notify the beneficiary—using oral, telephone, e-mail, fax, or letter format—that you have received the complaint and that you are investigating. Within 14 calendar days, you must provide written notification to the beneficiary of the results of your investigation and response. You also must maintain documentation of all complaints that you receive, copies of the investigations, and responses to beneficiaries. This is going to take complaint reporting at most HMEs to a new level, with careful time-stamp documentation of the date that the complaint was received, and the date that the customer was provided with a follow-up report.
4. Providers of high-end rehab seating and mobility systems must have proof that at least one qualified RTS is on location; and the rehab techs must have documented proof of 10 hours of in-service/continuing education specific to rehab technology.

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Historically, most accreditation organizations turned a blind eye to any HME service provided except rental medical equipment that had been delivered to the patient's residence. All this changed last year when accreditation organizations became "recognized" by Medicare as part of the mandatory accreditation process for competitive bidding. Now Medicare requires that the next time you see an accreditation representative, the surveyor must review any service that is billed on behalf of the patient—regardless of whether the customer walks in the door to pick it up or it is sent as a mail-order supply.

Even if your company never bills Medicare, the accreditation organizations are going to apply the CMS quality standards consistently to eligible services, regardless of what insurance company or government agency is billed. In particular, prosthetics such as mastectomy products, orthotics (either off-the-shelf or custom fabricated), surgical supplies including wound care, diabetic strips, and urologicals will now be included in the survey process.

Vianna Zimbel, RCP, specializes in accreditation and regulatory consulting for the HME industry. For more than 15 years, her consulting business has successfully guided hundreds of companies through standards interpretation. Zimbel can be reached via e-mail: .