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 ConwayPresident

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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

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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

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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

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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

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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)

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Why is this happening?

• High profile fraud and abuse cases

• New price list alone will not solve

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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 www.dmecometitivebid.com

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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

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Next 80 Largest MSA’s

Los Angeles New York Chicago San DiegoWashington, DC St Louis, MO/IL Richmond, VA LouisvillePhoenix Seattle Houston AtlantaNassua/Suffolk Oakland, CA Denver Newark, NJPortland, OR Ft Worth, TX Las Vegas San Jose, CABoston Indianapolis San Antonio Virginia

BeachColumbus, OH Milwaukee Bergen, NJ New OrleansSalk Lake City Greensboro, NC Austin NashvilleProvidence. RI Raleigh/Durham Hartford BuffaloMiddlesex/Somerset Memphis W Palm/Boca Monmouth

Jacksonville Rochester, NY Grand Rapids FresnoPhiladelphia, PA San Francisco, CA Tampa Detroit

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Next 80 Largest MSA’s Con’t

Oklahoma City Greenville, SC Dayton, OH HonoluluAlbany Tucson Tulsa Ventura, CASyracuse Omaha Albuquerque AkronKnoxville El Paso Bakersfield Gary, INAllentown, PA Harrisburg Scranton Toledo, OHJersey City Baton Rouge Youngstown, OH Springfield, MALittle Rock Ann Arbor Stockton, CA WichitaCharleston New Haven, CT Mobile, AL Columbia, SC

McAllen/Edinburg, TX Sarasota/Bradenton

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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

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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”

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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

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Final Product Categories 1. Oxygen Supplies and Equipment2. Standard Power Wheelchairs, Scooters

and Related Accessories3. Complex Rehab Power Chairs and

Related Accessories4. Mail Order Diabetic Supplies5. Enteral Nutrients, Equipment and

Supplies6. CPAP, RAD’s and Related Supplies and

Accessories7. Hospital Beds and Related Accessories8. Negative Pressure Wound Therapy

Pumps and Related Supplies and Accessories

9. Walkers and Related Accessories10. Support Surfaces (Groups 2 mattresses

and overlays) in Miami and San Juan only

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Product Selection

• CMS selected products for CB based on:– High cost

– High-volume

– Greatest potential for savings

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Legislative Activity

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What’s the update from the First 10 CBA’s?

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Deadlines wereVERY 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

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Multiple Bidding Issues

• Geographic area in each was VERY extensive

• Capacity issues- wait to be seen who is awarded bids

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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???

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Must HavePerformance Management1. Beneficiary satisfaction surveys

2. Patient complaint log

3. After hours (on call) log to prove timeliness of response to questions, problems and concerns

4. Log that documents frequency of billing and/or coding errors

5. 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

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Performance Improvement Examples are Everywhere…

Where do you see them?

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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

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Comparing “Apples-to-Apples”

Product Category DefinitionsDME 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

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Accreditation Commission for Healthcare (ACHC)

www.achc.org

DME- All Equipment

Medical Suppliers (Pharmacies)

Respiratory

Rehabilitation

Orthotics and Prosthetics

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American Board of Certification for Orthotics and Prosthetics (ABC of O&P)

www.abcop.org

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 (www.cpeds.org)

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Board of Orthotic/Prosthetist Certification (BOC)

www.bocusa.org

DME- All Equipment

Medical Suppliers (Pharmacies)

Respiratory

Orthotics and Prosthetics

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Commission on Accreditation of Rehabilitation Facilities (CARF)

www.carf.org

Rehabilitation

Orthotics and Prosthetics

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Community Health Accreditation Program (CHAP)

www.chapinc.org

DME- All Equipment

Medical Suppliers (Pharmacies)

Respiratory

Rehabilitation

Orthotics and Prosthetics

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The Compliance Team

www.exemplaryprovider.com

DME- All Equipment

Medical Suppliers (Pharmacies)

Respiratory

Rehabilitation

Orthotics and Prosthetics

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Healthcare Quality Association on Accreditation (HQAA)

www.hqaa.org

DME- All Equipment

Medical Suppliers (Pharmacies)

Respiratory

Rehabilitation

Orthotics and Prosthetics

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Joint Commission (JCAHO)

www.jcaho.org

DME- All Equipment

Medical Suppliers (Pharmacies)

Respiratory

Rehabilitation

Orthotics and Prosthetics

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National Association of Boards of Pharmacy (NABP)

www.nabp.net

DME Limited- Wound Care/Incontinence, Mobility Aids

Medical Suppliers (Pharmacies)

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National Board of Accreditation for Orthotic Suppliers (NBAOS)

www.nbaos.org

Orthotics and Prosthetics

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Models/Formats

Models/Format of Programs

• Additionally– Paper Based vs Electronic

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Video Examples

• Anxiety about the Surveyor

• Home Visit

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Home Visits

GO OUT AND SEE WHAT’S HAPPENING!!!

Surveyors will interview patients, asking how they were oriented, how to reach the office, how the

services has been, any problems…

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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

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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

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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!)

www.vgmeducation.com/shop

www.accreditationresources.com

5. Identify your team(s)--- review the standards by team and identify what you need to do

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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!

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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

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The Most Effective Way to Survive and Thrive in Your

Business is to

Be Prepared

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Your Questions ???

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Thank You!

Mary Ellen Conway

President

Capital Healthcare Group, LLC

Bethesda, MD

301-896-0193

www.capitalhealthcaregroup.com