The drop-dead date for mandatory accreditation is September 30, 2009. If you have not already done so, it is time to pull yourself up by your bootstraps and begin the accreditation preparation process. There is a sense of urgency, as there has been for some time, but with CMS' announcement, it is real. Existing DMEPOS suppliers enrolled in the Medicare program are required to have completed the accreditation survey/processes (have been granted accreditation status) and obtained and submitted an approved accreditation to the National Supplier Clearinghouse (NSC) by September 30, 2009.

New DMEPOS suppliers who have enrolled for the first time before March 1, 2008, must obtain and submit an approved accreditation to the NSC by January 1, 2009.

New DMEPOS suppliers submitting an enrollment application to the NSC on or after March 1, 2008, must be accredited prior to submitting the application. The NSC will revoke a DMEPOS supplier's billing privileges if the supplier fails to obtain and submit support documentation that they are accredited.

Accreditation will provide much more than satisfying CMS and retaining your billing privileges for reimbursement. CMS is not the only payor you are involved with. Mark my words; if history repeats itself, the third-party payors will all follow CMS' lead. It is inevitable.

On a more positive note, remember that accreditation is intended to improve your company's business model by providing you with the tools to achieve elevated quality service and, ultimately, improved patient care and safety.

There is no quick accreditation process. Allow yourself 4 to 6 months to be ready for the survey. If you are considering an accreditor or a consultant who implies they can push you through the process with minimal effort, remember that what sounds too good to be true usually is. Don't go there.

Becoming accredited is not extremely difficult, but does require time, commitment, and a team approach. You are already completing many of the accreditor's requirements during your daily operations; they will need to be reviewed to make sure you're meeting the accreditor's standards, and are following your own policies and procedures.

The old horror story about the accreditation survey and the surveyors being on a witch hunt is just that. The surveyors and accreditors of today take an educational approach and want you to succeed. They are looking for what you are doing right, not what you are doing wrong.

Achieving accreditation promotes quality throughout the entire organization, with an overall view of your company top to bottom—starting with management—to the company's core values. This should be your main incentive in becoming accredited, along with satisfying CMS and competitive bidding.

Prior to choosing an accreditor, check with your third-party payors before making a commitment. During my travels as a consultant, I have learned that several state payors and insurance companies will accept accreditation only from the major, well-established accreditors. You should also set up an ongoing relationship with the accreditor; feel free to call them after the survey to ask any questions.

Your accreditor's standards will change approximately every 2 years, CMS will be refining the quality standards, and changes in federal laws and regulations could affect your policies and procedures.

Wayne M. Link

I have heard from provider organizations, during either survey or consulting, that these accreditation standards are intended for large providers, not small ones. "We will have to hire an additional employee just to keep up with all of this," they say—but this is not so. The core and scope of service standards required by the major accreditors are designed to promote high-quality services and equipment as well as patient and employee safety. In essence, accreditation raises the industry level of professionalism so that the public and medical community view us as a paramedical adjunct to home medical care.

Once all the accreditation standards are in place and you adjust your daily regime, you will see that you are more organized and productive. Ask any time management advisor and they will tell you we all waste approximately 20% of our day doing nonproductive tasks. Once you feel comfortable and get into a routine with documenting and monitoring some additional processes, set a schedule (annually) for in-service education, performance improvement, corporate compliance, and staff meetings. You will see that it is all worth it.

Some providers do have a policy and procedure manual in place, and some do not. The policy and procedure manual must address your chosen accreditor's standards, and your company must be in sync with this directive. Update your policy and procedure manual to include the latest updates from CMS and/or your accreditor. If you choose to produce your policy and procedure manual in-house, you must evaluate your internal resources to decide if this is a cost-productive move, or if it is more efficient for you to purchase a customized manual. Before making a purchase, thoroughly research the author or publisher and verify with your chosen accreditor that this manual meets their standards. Also, talk to other satisfied companies to get their referrals regarding applicability to their business.

Prior to survey, you need to have at least 4 months of solid historical data addressing the specific accreditor standards. A few examples are:

1. patient/client charts or files;
2. employee personnel records;
3. corporate compliance plan;
4. performance management program;
5. preventive maintenance files;
6. equipment cleaning/disinfection log; and
7. operational verification of equipment functionality log.

Unless you want to be operating under the gun with the pressure of preparing a bid for competitive bidding in round two and/or preparing for the accreditation process, you would be wise to begin the process today. Learn from the scramble that providers went through during the first round of competitive bidding. Don't procrastinate any longer. The accreditors more than likely will have a backlog of surveys to schedule. Each accreditor has a limited number of surveyors and office staff to accommodate this large influx of providers requesting accreditation.

If you choose to hire help, an on-site consultant who visits for a day or two for a compliance audit or a mock survey can easily distinguish the forest from the trees. This in itself can keep your company from being deferred or denied accreditation and may prevent a delay.

Wayne M. Link, RCPT, RCP, is president of Link Consulting Group, an accreditation consultant, a lecturer, and a senior surveyor for the Accreditation Commission for Health Care (ACHC).