How to Proceed if You Miss the Accreditation Deadline
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In case you haven’t been around for at least the past 18 months or so, there has been a steady drumbeat signaling the approach of the Sept. 30 accreditation deadline.
What accreditation means is that a provider meets a set of various standards, based on the equipment and services it provides. The process, as well as the cost it entails, ensure the provider is a responsible, “bona fide” provider of home medical equipment, and can bill Medicare for reimbursement. Without certification, an HME must find other sources of revenue.
The goal of the program is to reduce Medicare fraud by making it impossible for shady businesses from making bogus claims. It also has a secondary payoff of helping providers integrate more efficient processes, documentation and equipment handling, which should reduce their operational costs and help preserve their margins (an important consideration in these days of dwindling reimbursement). These are win-wins for the industry.
However, the accreditation process can take between four and six months on average, which puts any provider that is only now considering getting accreditation certification well past the point where they will make the Sept. 30 deadline. What should they do in that case?
Know where you stand. If you have started the accreditation process and are hoping to make the Sept. 30 deadline, you should be ready to engage in a site survey. The site survey is essentially the final step in a long period of preparation, and is a sort of surprise quiz by surveyors from an accreditation organization in order to review a provider’s business to make sure it meets all the necessary accreditation standards.
If your business still has much more preparation work to do, it might not be able to make the deadline. Now is the time to confer with your accrediting organization and see what is possible. For instance, if you’re only 15 days away being be able to complete a site survey, you might stand a chance of making the deadline. The key will be to prioritize what it is you need to do and to streamline the process as much as possible to ensure you make it in under the gate. For more information on how to do that, read “How to Streamline the Accreditation Process.”
Thinking of starting now? Don’t. The window of opportunity to join in the accreditation fray is pretty much closed at this point. Already, accrediting organizations have been working with thousands of providers, and now they are also working on accrediting thousands of pharmacies and subcontracted partners. The volume of work to be done and paperwork to be processed will surely consume the next 90 days. Bottom line, you need to start thinking about what comes next.
What if you can’t make it? If a provider does nothing between now and the Sept. 30 deadline, it will risk having its supplier number revoked, plain and simple. That is an unsettling prospect, but then, perhaps the provider has decided that it is changing its revenue strategy altogether. In any case, it will be unable to bill Medicare come Oct. 1.
But, if a provider still considers Medicare funding a key element of its business, then the answer are less clear. The first thing is to try and keep your supplier number, rather than have it revoked by the National Supplier Clearinghouse (Palmetto GBA).
Staying in the game. Perhaps the best strategy for providers wishing to continue billing, but that will not make the Sept. 30 deadline is to submit a CMS 855S enrollment form, essentially withdrawing their supplier number from billing Medicare. This is not the same as having the number revoked. The provider still retains the number, but is unable to bill Medicare. What is uncertain is what happens after that, as CMS and the industry are entering uncharted territory.
Reentering Medicare and accreditation. Be aware that when you decide to reenter, it is undetermined as to how long it will take to get back in the game. This is largely up to the NSC, which ensures providers seeking billing privileges meet the standards set forth in title 42 of the Code of Federal Regulations 424.57. Those regulations also document appeals rights for providers who have had their billing privileges revoked. A lapsed provider would have to reenroll and reapply for accreditation and that could take some time, especially giving the number of companies queuing up at the accrediting organizations and at the NSC. Undoubtedly, there will be a backlog of providers and paperwork bottlenecking the process.
As of its most recent, March 26 update, NSC says that each month it selects roughly 1/12 of the supplier population required to reenroll during that calendar year. Depending on how heavy or light NSC’s workload is, as well as the number of providers selected to reenroll, some providers might receive their reenrollment packages a month or two earlier or later than the one-year anniversary date of either the issuance of their supplier number or the date of their last reenrollment. But if many providers miss the Sept. 30 deadline, that schedule could change entirely.
Points to take away:
- Determine where you are in the process. If you’re only now starting with accreditation, you’re too late.
- There are two main options if you cannot make it: do nothing and have your supplier number revoked, or withdraw your supplier number in hopes of reenrolling.
- Reapplying and reenrolling with the National Supplier Clearinghouse is at press time an unknown in terms of how long it will take, as well as the specifics on how the process will work.
- Details on enrollment with The National Supplier Clearinghouse, including a detailed FAQ that discusses reenrollment and other issues that could become pertinent to providers who miss the Sept. 30 accreditation certification deadline can be found at the NSC web site. Visit: http://www.palmettogba.com/nsc
- Also, read more about accreditation on the Accreditation Solution Center. Visit: http://hme-business.com/portals/accreditation.aspx
This article originally appeared in the July 2009 issue of HME Business.