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.

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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,
2007MedTrade.

• Mary Ellen Conway
• President

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Overview

• What is the Accreditation Requirement?
• First 10 MSAs, Next 70
• When do YOU Need to be Ready?
• Current Important Legislative Activity
• Inconspicuous Items
• Report from the First 10 CBAs

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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 DMEs 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 CBAs 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 CBAs

• 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 MSAs

• 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

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Next 80 Largest MSAs Cont

• 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

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The CBA (Competitive Bid Area)

• Can be multiple MSAs
• 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 MSAs
• You must be accredited by some finite date

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• 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, RADs 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

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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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Whats the update from the First 10 CBAs?
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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
  CBAs- could be before the first round contracts
  begin
• Herb Kuhn, AAHC Legislative Conference, June 6

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How Do I Get Started???
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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

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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 accreditors 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
  organizationyour perceptions
• Your peers experience

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The Current Ten Recognized AccreditorsNot every
organization is an option for you
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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

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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 OP)

• www.abcop.org
• Orthotics and Prosthetics
• DME Limited- Wound Care/Incontinence, Mobility
  Aids only if in conjunction with OP
• 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 WHATS 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 accreditors standards ASAP
• 4. Review and update your PP (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 youre ready!

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• Stay Tuned!
• Watch for updates in the media on a weekly basis
• Release of the next 70 CBAs (can be multiple
  MSAs)
• Conferences held by the CBIC to instruct
  beneficiaries
• Pricing for items for bid in the first CBAs

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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