Observation Deck

The DMEPOS Documentation Tour

An operations approach to 'getting it done.'

No single healthcare business sector has felt government and private thirdparty payor demands for greater patient-provider documentation moreacutely than the DMEPOS industry.

Given the plethora of documentation mandates from government and private-sector sources that challenge small and large businesses alike, it is critical for providers to stay up to date with ever-changing documentation requirements that often mean thedifference between getting paid for goods and services rendered or not.

Admittedly, there is an overlapping and at times overwhelming complexity to the federal and state government documentation regulations that impact on DMEPOS providers. Add to that documentation requirements issued by third-party payorsand it is easy to see why folks get frustrated.

As part of our on-going effort to simplify the accreditation process, The Compliance Team goes about validating that mandatory documentation requirements are met in a decidedly pedestrian way. That is, we literally take a tour of thefacility when we do an on-site accreditation evaluation.

What follows is a basic outline of a typical accreditation “tour” and the documentationthat we look for when we visit a provider:

Reception area — Hanging on the wall or as a door decal, the facility’s business hours and services. Postings in lobby should include CMS DMEPOS Supplier Standards, privacy notice, business licenses if applicable; accreditation certificate; exits marked; emergency preparedness plan; and an evacuation plan. A company flyer, rack brochure or specific documents that list business hours and services; products offered; after hours services; who to call in an emergency; how to file a complaint; and of course company contact info as well as website; and email URLsare required.

Administration/Leadership of the Organization — At the heart of any organization are the people that own and /or run it. As the nerve center of the business, this department should have documents that tell the story about the Company and describe the business model. There need to be documents showing who formed the company and who owns it currently if that has changed; who is in charge of everyday operations; a list of employees and their responsibilities; what are the business and service goals of the company; a mission statement; and financial statements. There, should be documents that describe how you deliver the services you promise; the customer population you serve; and how you are meetingthe goals you set for the company.

Is the company utilizing subcontractors for delivery and instruction? What contract do they have in place to back it up? Your policy and procedure manualshould describe how various jobs get done and who is responsible to do them.

Also required are various accreditation documentation that pertain to administration and leadership, such as proof of ownership; organizational chart with lines of authority; financial statements including an operating budget and P&L; company policy and procedure manual; corporate compliance plan; standards of conduct;emergency preparedness plan; and a business associate agreement

Personnel/ Human Resource files — Written applications or resumes on all employees or independent contractors need to be on file. This file should also contain evidence of documented training as it relates to their job description. (Trainingdocumentation can be in the personnel file or a training binder.)

Depending on what type of equipment or services provided, there are certain things that require mandatory documentation that proper employee training was conducted such as training associated with OSHA Right to Know; Blood-borne Pathogen and TB testing as well as emergency preparedness, fire safety, lifting etc. Job descriptions, performance evaluations, health status letters, verification ofprofessional licenses also need to be on file.

Order Intake Area —There must be a form relating to the description of the order from the doctor for the DMEPOS item. Payor source is verified at this juncture as well as contact information for the patient. Elements of the order as required by the payor source should be present and verified. Doctor’s licenses need to be verified with an expiration date if not on file. Documentation that shows the doctororder from matches what was delivered.

Billing — All billing records must be documented according to Medicare or DMAC requirements. There needs to be a Patient Agreement form. The organization has a patient agreement or assignment of benefits form, which outlines the charges and is given to the patient at the time of delivery. This statement mustinclude “ I authorize any holder of Medical Information about me to release to<Provider>, my physician (s), caregiver, CMS or its agents” as part of the statement.

Equipment Management — There should be a complete history on all serialized equipment that can be easily accessed. The information must include where the device is located in the event of a recall. (Knowing where your assets are at all times is an added benefit.) It is also important to know all of the patients that have used that device so that you can track how often the device is in use as it relates tobreakdown and need for maintenance.

Manufacturer guidelines must be followed and available for review. An equipment history record should also document all repairs and preventative maintenance as well as when regular service checks are scheduled. If a device breaks down you want to document what the problem was; what was fixed and when it is ready to be “Patient Ready” again; and document that fact so that there is no question that it issafe for another patient to use again.

There needs to be signage in the warehouse regarding areas designated for clean (patient ready); dirty/clean/repair/obsolete/broken areas. Everything needs to be labeled. Equipment needs to be tagged clean or dirty, and when it was last inspected. Keep in mind that all equipment should be inspected prior to delivery;thus ensuring it is in working order and patient ready.

Quality Improvement — One area that ties all business activities together is Quality improvement. There should be a written QI plan that identifies improvement activities. There should also be a “Patient Satisfaction” survey tool; a Complaintform; meeting minutes; and claims monitoring forms.

Risk Management — Every company wants to keep risks low. If there is an incident of a patient or employee getting injured then there needs to be documentationon an Incident report.

Patient Services — A healthcare organization’s approach to patient care is reflected in the files (documentation) that it uses every day. It goes to the heart of your business. It should tell a story of everything that a particular patient hasreceived from your company and why.

There should be a plan-of-care/service identifying the equipment ordered and delivered; how the patient is to use it; clean it; maintain it and who to call to get it fixed if it should break. (Troubleshooting tips should be included with reasons for when the patient should call the provider.) The file must include receipt of privacy notice (HIPAA), rights and responsibilities, CMS’ supplier standards, and of course,the patient agreement and what was billed.

Exit statement —That’s it, the tour is over. Hopefully, now you will have a better understanding of what important documentation is looked at as part of an accreditor’svalidation tour of your facility.

This article originally appeared in the October 2012 issue of HME Business.

About the Author

Sandra C. Canally, RN is the founder and CEO of accrediting organization The Compliance Team Inc., which was approved by CMS in 2006 to accredit all types of DMEPOS businesses. For more information, email scanally@TheComplianceTeam.org, or visit TheComplianceTeam.org.

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