Monday, May 26, 2008

Facilty Accreditation

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    What Does It Mean To Be Accredited Per the CMS Guidelines?



For those who plan on drawing a chalk line around Facility Accreditation, think again. Although On September 3rd, CMS stated that facility accreditation for professionals, including physicians, PTs, OTs, qualified speech therapists, physician assistants, nurse practitioners, nurse midwives, orthotists, prosthetists, pedorthists, podiatrists, optometrists and opticians are exempt from the September 30, 2009, mandatory accreditation deadline, they also, stated that this action is only a delay. Accreditation requirements and quality standards will be revised for Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) will be issued in 2009. I am concerned that the new standards will be more onerous than the old.

CMS Reverses it statement on C-Ped exemption from AccreditationWritten Clarification on Medicare for Patients and Providers Act of 2008 (MIPPA)
MIPPA section 154(b) added a new subparagraph (F) to section 1834(a)(20) of the Social Security Act. This subparagraph states that eligible professionals and other persons are exempt from meeting the September 30, 2009 accreditation deadline that generally applies to other DMEPOS suppliers unless the Centers for Medicare & Medicaid Services (CMS) determines that the quality standards are specifically designed to apply to such professionals and persons.
The eligible professionals to whom this exemption applies are set out at sections 1848(k)(3)(B) and 1861(r) of the Act, and include Physicians, Physical Therapists, Occupational Therapists, Qualified Speech-Language Pathologists, Physician Assistants, and Nurse Practitioners.
Additionally, section 154(b) of MIPPA allows the Secretary to specify “other persons” that, like the eligible professionals described above, are exempt from meeting the accreditation requirements unless CMS determines that the quality standards are specifically designed to apply to such other persons. At this time, we are defining “such other persons” as Orthotists, Prosthetists, Opticians, and Audiologists.
CMS will define how the quality standards apply to these eligible professionals and other persons by rulemaking in 2009.
Individuals not included in this exemption list, such as pedorthotists, mastectomy fitters, orthopaedic fitters/ technicians or athletic trainers applying for Medicare enrollment in order to bill for Medicare part B services are not exempt from meeting the September 30, 2009 deadline for DMEPOS accreditation.



With the Medicare Modernization Act, CMS implemented new standards of patient care and fraud protection over the entire orthotic, prosthetic, pedorthic and DME market. These new standards require all DME suppliers to submit to mandatory facility accreditation – and CMS is going to rely on independent organizations ( see the list to the right) to verify compliance against established Medicare Quality Standards. The Standards are grouped into seven categories. Accreditation decisions are based on the degree of conformity with each Standard. The categories are:

  • Administration; this standard deals with governance, what legal form the organization has taken, idenditfing the leadership of the organization, development od policies and procedures, physical location of organization, scope of practice.


  • Financial Management; financial practices that ensure accurate accounting and billing.

  • Human Resources; written policies to specify personnel qualifications, training, experiences and continuing eduction



  • Consumer Services; the standards designed to support the delivery of high quality patient care – and to ensure that patient needs are met.



    Performance Management; the standards associated with the assessment and improvement of the delivery of patient care services.



    Product Safety; supplier to implement an equipment and item management program that promotes their safe use and minimizes risk.



    Information Management; system in place to maintain accurate, pertinent, accessible, confidential and secure patient records.

    A complete list of Supplier Quality Standards is listed below





    WE CAN HELP!

    There are companies that provide the framework of the requirements for accreditation, such as OPGA. Their Policy and Procedure Manual provides a frameworks allowing you to set up the necessary policy and procedures to meet accreditation standards. But what about your physical facility, safety procedures, quality assessment and improvement and patient records?

    For a very low fee we will evaluate all of your compliance materials and perform a comprehensive on site mock facility survey. This can be a great way to reduce your stress and feel confident that you and your staff are prepared for that unannounced accreditation survey. With over 150 points of interest, we will provide:



    1. Evaluation of your policy and procedure manual

    2. Patient care and management assessment

    3. Evaluation of your quality assessment and improvement program

    4. Safety inspection with emphasis on emergency preparedness

    5. On site mock facility survey

    6. A written report with practical solutions

    You can be confident that all information is held in the strictest confidence. We will have a signed confidentiality agreement in your hands before we do anything.