CMS Accreditation Update - The Latest from the MSAs:
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CMS Accreditation Update - The Latest from the MSAs: CMS Accreditation Update - The Latest from the MSAs: Presentation Transcript

  • CMS Accreditation Update - The Latest from the MSAs: What Do You Need to Do and When Do You Need to Be Ready? Tuesday, October 2, 2007 MedTrade . Mary Ellen Conway President
  • Overview
    • What is the Accreditation Requirement?
    • First 10 MSA’s, Next 70
    • When do YOU Need to be Ready?
    • Current Important Legislative Activity
    • “ Inconspicuous Items”
    • Report from the First 10 CBA’s
  • Overview Continued
    • How Do You Get Started?
    • Tips on Choosing Your Accreditor
      • Issues with fees/costs
    • The Current Ten Recognized Accreditation Providers
    • Models/Formats
    • Video Examples
    • Main Reasons Organizations Fail
    • How Long Does It Take?
    • Ten Things You Can Do Now to be Ready
  • Common Acronyms
    • CBA Competitive Bid Area
    • CBIC Competitive Bidding Implementation Contractor
    • CMS Center for Medicare Medicaid Services
    • DME Durable Medical Equipment
    • DMEPOS Durable Medical Equipment, Prosthetics, Orthotics and Supplies
    • HME Home Medical Equipment
    • MMA ’03 Medicare Modernization Act of ’03
    • MSA Metropolitan Statistical Area
  • What is the Accreditation Requirement?
    • The Medicare Modernization Act of 2003 (MMA ’03) states that ALL DME Providers billing Medicare for identified Part B products must be accredited by 2007--- this will be enforced initially through the Competitive Bidding Requirement
    • There are between 117,000 and 150,000 Medicare Part B supplier numbers
    • This applies to DME’s as well as pharmacies billing for identified items
  • The “Dominos”
    • CMS is enforcing the law that requires competitive bidding in 2007
    • (Slated to begin July 2008)
    • Only accredited organizations can be awarded a bid
    • Accreditation must be by recognized accreditors
    • Provider must comply with Final Quality Standards (Released 8-14-06)
  • Why is this happening?
    • High profile fraud and abuse cases
    • New price list alone will not solve
  • Competitive Bidding Timeline
    • Bidding opened May 15, 2007
    • Bidding closed September 26, 2007
    • Competitive bidding contracts will be awarded for 3 years (with the exception of mail order diabetic supplies), starting July 1, 2008 in the identified 10 CBA’s and in a additional 70 (for a total of 80) to begin July 1, 2009
    • See website
  • The First 10 CBA’s
    • Charlotte-Gastonia-Concord: NC-SC
    • Cincinnati-Middletown, OH-KY-IN
    • Cleveland-Elyria-Mentor, OH
    • Dallas-FT Worth-Arlington, TX
    • Kansas City, KS-MO
    • Miami, Ft Lauderdale, Miami Beach, FL
    • Riverside, San Bernadino, Ontario, CA
    • Orlando, Kissimmee, FL
    • Pittsburgh, PA
    • San Juan, Caguas, Guaynabo, Puerto Rico
  • Next 80 Largest MSA’s
    • Los Angeles New York Chicago San Diego
    • Washington, DC St Louis, MO/IL Richmond, VA Louisville
    • Phoenix Seattle Houston Atlanta
    • Nassua/Suffolk Oakland, CA Denver Newark, NJ
    • Portland, OR Ft Worth, TX Las Vegas San Jose, CA
    • Boston Indianapolis San Antonio Virginia Beach
    • Columbus, OH Milwaukee Bergen, NJ New Orleans
    • Salk Lake City Greensboro, NC Austin Nashville
    • Providence. RI Raleigh/Durham Hartford Buffalo
    • Middlesex/Somerset Memphis W Palm/Boca Monmouth
    • Jacksonville Rochester, NY Grand Rapids Fresno
    • Philadelphia, PA San Francisco, CA Tampa Detroit
  • Next 80 Largest MSA’s Con’t
    • Oklahoma City Greenville, SC Dayton, OH Honolulu
    • Albany Tucson Tulsa Ventura, CA
    • Syracuse Omaha Albuquerque Akron
    • Knoxville El Paso Bakersfield Gary, IN
    • Allentown, PA Harrisburg Scranton Toledo, OH
    • Jersey City Baton Rouge Youngstown, OH Springfield, MA
    • Little Rock Ann Arbor Stockton, CA Wichita
    • Charleston New Haven, CT Mobile, AL Columbia, SC
    • McAllen/Edinburg, TX Sarasota/Bradenton
  • The CBA (Competitive Bid Area)
    • Can be multiple MSA’s
      • Applies to defined Zip Codes where the beneficiary resides , not where the provider is located
      • Check CBIC website for service area zip codes- can be an enormous service area
  • When Do You Need to Be Ready?
    • If you provide any of the identified products or services to Medicare beneficiaries in any of the defined areas and wish to continue, you will be required to bid.
    • In order to bid, you will need to be accredited
    • If you do not bid, or do not win the bid, you are excluded for three years- you CAN NOT bill from an office in another area
    • All others may be required to be accredited (whether or not there is Competitive Bidding in your service area) as early as April 1, 2009 “Everyone else after that”
  • What if You Provide Products and Services in Rural Areas Only?
    • You may never have to participate in Competitive Bidding
    • You will get a rate adjustment as CMS will begin to reimburse providers the rates paid in the closest MSA’s
    • You must be accredited by some finite date
    • Final Product Categories
    • Oxygen Supplies and Equipment
    • Standard Power Wheelchairs, Scooters and Related Accessories
    • Complex Rehab Power Chairs and Related Accessories
    • Mail Order Diabetic Supplies
    • Enteral Nutrients, Equipment and Supplies
    • CPAP, RAD’s and Related Supplies and Accessories
    • Hospital Beds and Related Accessories
    • Negative Pressure Wound Therapy Pumps and Related Supplies and Accessories
    • Walkers and Related Accessories
    • Support Surfaces (Groups 2 mattresses and overlays) in Miami and San Juan only
  • Product Selection
    • CMS selected products for CB based on:
      • High cost
      • High-volume
      • Greatest potential for savings
  • Legislative Activity
  • What’s the update from the First 10 CBA’s?
  • Deadlines were VERY tight
    • Many suppliers had their applications and funds returned at the end of June/beginning of July (before the extension was announced) from accreditors
    • For many who were surveyed in time, they had extensive amounts of follow-up that needed to be done due to incomplete work. This often included re-visits
    • All has to be complete by October 31st
  • Multiple Bidding Issues
    • Geographic area in each was VERY extensive
    • Capacity issues- wait to be seen who is awarded bids
  • The Next 70?
    • Complaints in Florida about 20 minute accreditation surveys
    • Results of validation surveys?
      • PAOC Meeting scheduled for October 11, Baltimore, MD
    • CMS announced that they are ready for the next 70 CBA’s- could be before the first round contracts begin
      • Herb Kuhn, AAHC Legislative Conference, June 6
  • How Do I Get Started???
  • Must Have
    • Performance Management
    • Beneficiary satisfaction surveys
    • Patient complaint log
    • After hours (on call) log to prove timeliness of response to questions, problems and concerns
    • Log that documents frequency of billing and/or coding errors
    • Log documenting adverse events (as defined by your P & P manual)
    • Most accrediting organizations require at least three months of surveys collected and summarized with plans for improvement or you will have to provide written follow-up and possible a re-visit
  • Performance Improvement Examples are Everywhere…
    • Where do you see them?
  • Tips to Use in Choosing Your Accreditor
    • CMS is not your only payer!
      • Payer or state licensure requirements to be accredited ex: Anthem BC, State of Florida, Oklahoma Medicaid
    • What is the accreditor’s schedule and what are the requirements for in-between?
      • ex: Triennial and or annual updates
    • Fees paid vs. administrative costs
    • Other services (infusion, home health)
    • Process (electronic vs. paper)
    • Interview/discussions with accrediting organization—your perceptions
    • Your peer’s experience
  • The Current Ten Recognized Accreditors Not every organization is an option for you
  • Comparing “Apples-to-Apples”
    • Product Category Definitions
    • DME Limited Mobility Aids: Manual W/C, Cane, Walker, Crutches,
    • Stationary Commode Chairs, Wound Care and Ostomy Supplies Urological Supplies: Bedpans, Urinals
    • DME includes Limited and - Manual and Electric Beds, Traction Equipment
    • Medical Supplies- Diabetic Supplies, Enteral Products (Non-home visit items)
    • Respiratory- Home medical equipment and supplies covered include respiratory
    • equipment and supplies, oxygen, concentrators, reservoirs,
    • conserving devices, cylinders and oxygen accessories and supplies,
    • home invasive mechanical ventilators, respiratory assist devices,
    • continuous and intermittent positive pressure breathing devices,
    • nebulizers
    • Rehabilitation- Power Mobility devices including complex Rehab and Assistive
    • Technology
    • Orthotics and Prosthetics- Custom fabricated, custom fitted, custom-made orthotics, prosthetic
    • devices, somatic, ocular and facial prosthetics, therapeutic shoes, braces
    • and artificial limbs
  • Accreditation Commission for Healthcare (ACHC)
    • DME- All Equipment
    • Medical Suppliers (Pharmacies)
    • Respiratory
    • Rehabilitation
    • Orthotics and Prosthetics
  • American Board of Certification for Orthotics and Prosthetics (ABC of O&P)
    • Orthotics and Prosthetics
    • DME Limited- Wound Care/Incontinence, Mobility Aids only if in conjunction with O&P
    • Merged with the Board for Certification in Pedorthics (
  • Board of Orthotic/Prosthetist Certification (BOC)
    • DME- All Equipment
    • Medical Suppliers (Pharmacies)
    • Respiratory
    • Orthotics and Prosthetics
  • Commission on Accreditation of Rehabilitation Facilities (CARF)
    • Rehabilitation
    • Orthotics and Prosthetics
  • Community Health Accreditation Program (CHAP)
    • DME- All Equipment
    • Medical Suppliers (Pharmacies)
    • Respiratory
    • Rehabilitation
    • Orthotics and Prosthetics
  • The Compliance Team
    • DME- All Equipment
    • Medical Suppliers (Pharmacies)
    • Respiratory
    • Rehabilitation
    • Orthotics and Prosthetics
  • Healthcare Quality Association on Accreditation (HQAA)
    • DME- All Equipment
    • Medical Suppliers (Pharmacies)
    • Respiratory
    • Rehabilitation
    • Orthotics and Prosthetics
  • Joint Commission (JCAHO)
    • DME- All Equipment
    • Medical Suppliers (Pharmacies)
    • Respiratory
    • Rehabilitation
    • Orthotics and Prosthetics
  • National Association of Boards of Pharmacy (NABP)
    • DME Limited- Wound Care/Incontinence, Mobility Aids
    • Medical Suppliers (Pharmacies)
  • National Board of Accreditation for Orthotic Suppliers (NBAOS)
    • Orthotics and Prosthetics
  • Models/Formats
    • Models/Format of Programs
    • Additionally
      • Paper Based vs Electronic
  • Video Examples
    • Anxiety about the Surveyor
    • Home Visit
  • Home Visits
    • Surveyors will interview patients, asking how they were oriented, how to reach the office, how the services has been, any problems…
  • Main Reasons Organization Fail
    • Lack of Preparedness
    • Few Staff Aware of Process/Requirements
    • Lack of Focus and Follow-through
    • Main items:
      • Physician Orders
      • Infection Control
      • Incomplete HR Files
  • How Long Does It Take?
    • Generally at least 4 – 6 months from start to completion
    • Do you have everything you need?
      • Policies and Procedures, Educational Materials, etc.
      • How long will it take for you to get these in place?
    • Once you gather your information, how long will it take for you to coordinate and submit your materials?
      • Average is 2 – 3 months
    • When you notify your accreditation company that you are ready, how long until your survey?
      • Schedules are usually 45 – 60 days in advance-Surveys must be un-announced within a window of time that you are ready
  • 10 Things You Can Do
    • 1. Download and become VERY comfortable with the final quality standards---read them carefully
    • 2. Review and talk to your payers to make an informed decision as you choose your accreditation provider right away
    • 3. Send for your accreditor’s standards ASAP
    • 4. Review and update your P&P (or BUY one!)
    • 5. Identify your team(s)--- review the standards by team and identify what you need to do
  • 10 Things You can Do
    • 6. Educate the staff NOW- practice discussions
    • 7. Create/review your PI program NOW– begin to collect patient satisfaction data and implement the required logs ASAP--- Gather at least 3 mos of data before notifying accreditor that you are ready
    • 8. Review all patient education materials to see what you will need to update/change so that they match the final standards
    • 9. Review physical plant, warehouse, vehicles
    • 10. Perform a Mock Survey - make corrections
    • Notify your provider that you’re ready!
    • Stay Tuned!
    • Watch for updates in the media on a weekly basis
    • Release of the next 70 CBA’s (can be multiple MSA’s)
    • Conferences held by the CBIC to instruct beneficiaries
    • Pricing for items for bid in the first CBA’s
    • The Most Effective Way to Survive and Thrive in Your Business is to
    • Be Prepared
  • Your Questions ???
  • Thank You!
    • Mary Ellen Conway
    • President
    • Capital Healthcare Group, LLC
    • Bethesda, MD
    • 301-896-0193