September 30, 2009, is now squarely in the crosshairs for all providers who wish to bill Meidcare Part B in the future.
Just prior to the May 14, 2008, accreditation application deadline for round two of competitive bidding (extended to July 21,2008), HME Today hosted a podcast series. Listeners could download the MP3 file to their iPods, or simply listen from their computers. With the new extension, the information is still relevant, and we present it here for those who would rather read a transcription. In this issue, we feature comments from Sandra Canally of The Compliance Team and Tom Cesar of the Accreditation Commission for Health Care. In July, look for wisdom from three other top accreditation organization representatives.
Greg Thompson, editor, HME Today: Why should all providers—not just those in named MSAs—also be thinking of accreditation?
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| Sandra Canally |
Sandra Canally, president of The Compliance Team, Springhouse, Pa: At this point, there are so many thousands of providers that need to get accredited—at last count, we had more than 90,000. A lot of the DME industry does not understand that there is more far reaching appropriateness to people like physicians, orthopedic surgeons, podiatrists, optometrists, and ophthalmologists. We're dealing with large numbers for 10 accrediting bodies to take care of in a short period of time. The priority is to take care of those in the next 70 MSAs, but at the same time, we at the Compliance Team certainly are encouraging folks outside of those MSAs to sign up as well, because we don't want to get into a position where there's any backlog or waiting list. So far, we've been able to avoid such a thing because we have providers on two different tracks—but with the numbers that are out there, we need to encourage them to come forward now.
For all providers, accreditation improves their business. It forces them to look at their everyday operation and see where their strengths and weaknesses are, and how to correct those weaknesses. Our program is a measured, continuous quality improvement program. For anybody out there, accreditation is all about good business practices.
If providers don't want to get accredited, or don't need to do it for Medicare or competitive bidding, there are other payors out there too. A lot of the private pay organizations in managed care require accreditation to get on their network. A lot of the state Medicaid organizations are going toward accreditation. It's just good business practice.
Tom Cesar, president of the Accreditation Commission for Health Care (ACHC), Raleigh, NC: Regardless of the requirement that is now being imposed by CMS, a provider should view accreditation as a positive tool to raise their level of professionalism, to improve business policies, procedures and practices; in other words, strengthen their business model itself—to strengthen their marketing position with consumers. You're basically sending a message to consumers that you do care for quality and you do have outside peer review to assure them that you're doing it the right way, and you do what you say you're doing.
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| Tom Cesar |
It's an opportunity to acquire new learning. It's not just CMS that may be requiring this, but there may be other third-party payors, such as state Medicaid programs. Some have already made announcements; I understand Oklahoma and Georgia in recent months have made accreditation requirements. And certainly, some of the third-party payors like Blue Cross and Blue Shield regional companies have already begun to require accreditation.
Especially the company needs to realize that it's a chance to learn something about the company. We get busy doing our day-to-day work, and seldom step back to take self-assessment and see how well we are doing; where can we become more efficient, more effective; where can we save time; how can we get better customer services to the folks we work with? Accreditation helps you take a step back and take a look at the total operation, the total company, and the intent actually is to help you become a better organization, and a better provider of services to your customers. Admittedly, on the front end, if you've never been through the process, it's kind of scary. However, we've talked to folks at the other end who've completed their certificate, and they've made comments like, "This has been a big help."
HME Today: How soon after a provider applies does the survey take place, and how long does it take in general for a provider to finally achieve that accreditation?
Canally: An average of 3 to 4 months. Now, in the first round of competitive bidding and certainly in this next round, for those companies that sign up kind of late, we will have an accelerated track. So they could actually do it in 2 months. But a lot has to do with how they're doing on that end, and how quickly they can implement what we tell them to do.
If providers submit applications today, the first thing that's going to happen is that they are going to receive some preparation materials on a CD to guide them through the process, as well as an advisor. That advisor is going to schedule some conference calls over a period of a few months—typically, one a month—to lead them down the right path. So, I would say the average amount of time would be 3 to 4 months with them dedicating 3 to 4 hours a week to implementation.
When the standards are simplified so that providers can understand them, as well as everyone else in the organization—and when they're written in plain language and it's right in front of them—it takes them less time, and providers are more compliant because there are no surprises. I think that's an important point, because we want their focus to be on improving operations and better serving patients. So, we've purposely simplified not only the quality standards, but also the processes leading up to accreditation.
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Cesar: Typically, when small companies purchase an accreditation manual from one of the approved bodies, 4 to 8 months is not uncommon on preparation. Again, it depends on how much time they can really focus on the project; it can be less time. And if they hire a consultant, that could be reduced to 4 to 8 weeks. However, that's the preparation phase, and once you've prepared and have made your application, or sent in whatever information the accreditor requires, that triggers another step. That tells the accrediting body you've been preparing a number of weeks or months, you've reviewed things, you've implemented them, and now you're ready for on-site survey. And that on-site survey is simply a validation process to make sure you're doing what you say you're doing.
Once the accreditor has been advised by the company that they are now ready, and it may be that the contract is signed, the fees are paid, or at least a deposit (each of the accreditors operates a little bit differently), it can be anywhere from 4 to 6 months before you actually have a survey. Because of the crunch time that CMS has put on all of us, the accrediting bodies for the 70 MSAs will have to prioritize, so if an applicant comes in in the next few weeks and they're not in the 70 MSAs, we have to put them further down on the list for an accreditation survey, because the ones in the 70 MSAs must have the priority. So that 4- to 6-month time frame to actually have a survey is going to be a challenge for all the accrediting bodies.
Obviously, we've been gearing up with additional staff and improving processes, and we'll probably do [surveys] in a shorter time than we have typically been doing. Even in round one though, there were a couple of accrediting bodies that had to turn away applicants; they simply could not take any more applicants at that time. Your guess is as good as mine as to how many will actually apply in the next few weeks. It could be hundreds, it could be thousands, because there are a lot of companies out there with Medicare numbers. But typically, 4 to 5 months under normal circumstances [for a survey to take place].
As we face the bigger deadline date in September 30, 2009, it may sound like a long way away, but it's about 16 months now—less than a year and a half. If you put together the 4 to 5 months you prepare, another 4 to 5 months for an on-site survey, and then add to that whatever volume we're going to be facing, there could be a waiting list. It's possible this time next year that a company will have waited, they submitted an application with one of the accrediting bodies, and that accrediting body may say, "We have a waiting list and we can't get to you until December." That's where some have to be very sensitive not to put it off too long. And I think you know from what we've been reading over the last couple of years, part of CMS' initiative is not only to help curb fraud and abuse, but they want to reduce the number of companies that are actually Part B suppliers. They want to reduce that figure. And this is crunch time and the volume could actually make that come to pass.
HME Today: In what way does your organization go beyond what CMS mandates?
Canally: The brand that we have is "exemplary provider." So, just the word "exemplary" means that you're setting yourself apart from other providers that are just doing the minimum, or what is required. To accredit, they need to score 90% or better. So, already, we're setting the bar higher as our minimum standard.
Second, because of our focus on patient care and patient services, providers have follow-up requirements that other accreditors do not require. We also do 60-day follow-up, 6-month follow-up, and in between we collect patient satisfaction data for aggregation analysis—and then quarterly reports are sent back to the customer. This helps providers in dealing with managed care, and it tends to give them a lot more validity when the third-party accreditor is aggregating the data, as opposed to them. Most importantly, we evaluate providers on-site annually. The reason we do that, as opposed to the typical 3-year cycle, is to prevent patient issues and prevent problems from occurring. Because when the accreditor is on-site annually, with lots of follow-up in between, providers stay on track. Lastly, because of the status of being an "exemplary provider," providers can use that as a form of quality recognition branding for marketing purposes. That has helped a lot of our providers differentiate themselves from their competition.
HME Today: Are consultants needed to survive the accreditation process?
Canally: In our program specifically, they do not need to hire consultants. It's just not necessary because of how we simplify the process. Obviously, a lot of people want to do that. They feel that "Okay, I want to make sure I'm going to make that extra step. I'm going to bring in the consultant who is an expert in the field and can help us on-site to guide us through." However, is the company buying in to the accreditation process? Or are they letting and allowing the consultant to do everything? So when the consultant and the accreditor walk out the door, that's why some of the companies tend to go off track. Because they never bought into it to begin with.
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Cesar: Consultants are always going to be helpful, no question about that, because you have more hands on deck and they're there pushing things through for you. If time is not of the essence, though, I typically will advise companies to learn how to go through the process of preparation on their own. Simply because, if you have all your employees, even if it's five or six, and you divide up the standards you're required to comply with, you have a learning process for the company, number one; there's ownership to what they're doing, and when you are successful, it is a morale booster.
With a consultant, you lose a little bit of that, because someone from the outside is helping you do it. Obviously, I realize for companies that are in a push, it may be very wise to consider having a consultant come in, because the preparation times can be shortened when you have that extra person on hand; they've done it before. I'm sure there are quite a few consultant companies out there that have experience preparing organizations for any of the accreditors that have been approved by CMS. So, there are pluses to it, but there's an extra cost. It's not cheap to have a consultant, and that's important. If you do choose a consultant, make sure they have the experience in the mix of products and services that you provide to your customers.