As we are all aware, the industry received the final rule on competitive bidding in the early days of April. With this release, the news for many suppliers in the first 10 CBAs (competitive bidding areas) is that they have a lot of work to do in a short amount of time.

As you have read in previous issues of HME Today, the Medicare Modernization Act of 2003 states that all suppliers will have to be accredited to continue to bill Medicare for identified Part B products. Since then, we have learned that not all suppliers will be required to be accredited this year, but that the requirement for accreditation now applies to suppliers who are participating in competitive bidding in the first 10 CBAs. CMS requires that suppliers be accredited by the agencies recognized as "deemed status providers." In late November 2006, CMS named 11 (now 10) of these accreditation organizations. They are:

• Accreditation Commission for Health Care (ACHC)
• American Board of Certification of Orthotics and Prosthetics (ABC of O&P)
• Board for Orthotic/Prosthetic Certification (BOC)
• Commission on Accreditation of Rehabilitation Facilities (CARF)
• Community Health Accreditation Program (CHAP)
• The Compliance Team—www.exemplaryprovider.com
• Healthcare Quality Association on Accreditation (HQAA)
• The Joint Commission (JCAHO)
• National Association of Boards of Pharmacy (NABP)
• National Board of Accreditation for Orthotic Suppliers (NBAOS)

Requirements, fees, and work loads vary among the organizations, and not all accredit every type of supplier.

DME suppliers need to select from one of these 10 and need to become accredited by August 31 to be eligible to win a bid in the first round. The winning bidders are expected to be announced in the fall of 2007 for contracts that will begin April 1, 2008—but that contract will be awarded only if they are accredited.

DME suppliers must meet the final quality standards released by CMS on August 14, 2006. They can be found at: www.cms.hhs.gov...New_Quality_Standards.asp.

Mary Ellen Conway

Final quality standards are only 14 pages long and manageable. Compliance with the standards will be evaluated by the accrediting organization a supplier selects. Suppliers need to be busily working on their accreditation requirements now to finish by August 31. Currently, CMS requires that the approved accreditation providers submit monthly documentation to CMS showing all of the suppliers who are currently accredited as well as those that are "in process." In this manner, CMS will ensure that bidders are in the process and scheduled for accreditation surveys before the end of August, since CMS requires that the accreditors conduct unannounced surveys. To have an unannounced survey, suppliers must notify their accreditation agency that they are ready for survey, most likely by mid July to provide an adequate window of time to be complete by August 31.

THE MUST-HAVES

There are several items that I call "The Must-Haves" that providers need to comply with the final standards as well as their accreditation provider's requirements. These items are:

• a comprehensive policy and procedure manual that meets the requirements of the selected accreditation agency;
• complete and accurate paperwork for patients. Many suppliers have not reviewed their materials in years and would be surprised to see that some show addresses and phone numbers that are out of date, or that their delivery staff may be experts at getting delivery tickets signed, but routinely fail to get patients to sign all required paperwork and acknowledgments—as well as witness their signature;

The 10 Competitive Bidding Categories

1. Oxygen Supplies and Equipment
2. Standard Power Wheelchairs, Scooters, and Related Accessories
3. Complex Rehab Power Chairs and Related Accessories
4. Mail Order Diabetic Supplies
5. Enteral Nutrients, Equipment, and Supplies
6. CPAP, RADs, and Related Supplies and Accessories
7. Hospital Beds and Related Accessories
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
• updated/complete patient educational materials—the final quality standards are specific as to the requirements of appropriate educational materials;
• an adequate competency program that meets both the accreditor's and CMS' requirements; and
• a complete performance improvement program that gathers data on the five required items that CMS has indicated as the "minimum" required items to be collected.

Accreditation is a process that can generally take at least 4 to 6 months to complete. There is a tremendous amount of work that suppliers must accomplish to become accredited, and all of this must be accomplished in addition to normal business duties. Daily business duties don't go away, and suppliers have to find a way to get this work done as well as the time to do it.

Remember that MMA 2003 requires accreditation of all DME suppliers. We don't know what that "drop-dead" date will be, but rumor has it that it may be as early as April 1, 2009. In the meantime, suppliers in the first 10 CBAs need to be "in process" with their accreditation requirements right away to be accredited by the end of August.

For more information and articles on accreditation, see our free online archives. If you want to ask a free accreditation question, try our Expert Insight section. Sandra C. Canally, RN, president of The Compliance Team Inc, is available to answer any and all questions. Your e-mail will remain completely confidential and you will not be contacted for any reason. Answers can be found by clicking on Sandra's photo/section.

All other suppliers must get started as well. We have seen what a short notice CMS gave for the current bidding suppliers. It would not be a surprise to find another short notice for those in the next 70 CBAs.

Procrastination is not going to pay off. Working on the standards with plenty of time on your hands is the most effective way to ensure that you have enough time to do things right. Take a lesson from this first group and don't wait to be given a short deadline.

Many suppliers in this first group are struggling right now to become accredited by August 31, and many wish they had made the move sooner. If you are not in this first group, use the resources available through your state association, national association, and vendors.

Teleconferences and workshops can be extremely helpful to ensure that you focus on the right things and succeed. Suppliers are always pleased to have completed a successful survey without the added burden of waiting for another visit to follow up on items that were deficient. Whether or not you are in the first group, with proper planning and adequate allocation of time, you can be successful.

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.