Observation Deck

Identifying DME Deficiencies

Commonly found DMEPOS areas needing improvement from an AO’s perspective.

As one of the Medicare approved accreditation organizations, The Compliance Team representatives are in the field nearly every day of the year conducting on-site evaluations of DMEPOS providers who could be located anywhere in the USA’s fifty states, Puerto Rico or the U.S. Virgin Islands.

While on-site, our job is to verify and validate that our customers are meeting CMS’s DMEPOS Supplier and accreditation quality standards. We do this by using a weighted scoring document that directs us to look at all of the appropriate aspects of a provider’s specific product and service offerings.

To help shed some light on deficiencies that DMEPOS providers commonly share, we looked at our scoring data from on-sites conducted over the past six-months. What follows are common business operations that are areas that DMEPOS providers should pay particular care when addressing.

Equipment Management. One would assume that HME companies should excel in the area of equipment management as it relates to the Quality Standards. After all, “equipment” is their core business. Our scoring shows that is not necessarily the case. On average providers lost points in the following areas: segregating clean and dirty equipment; proper storage of equipment; not cleaning with an agent that kills Hep B and HIV; not following manufacturer guidelines for preventive maintenance; not tracking of equipment by serial number; not knowing the location of all equipment; improperly securing items during delivery; inappropriate storage in the warehouse; mishandling oxygen; not tracking repairs by type of breakdown or manufacturer model.

Infection Control. Infection control issues were mostly picked up during our evaluations while riding along on home deliveries. Lack of hand washing and gloving along with proper handling of dirty equipment were most often recorded as problem areas. The take away is that it is apparent that how infections are spread is not totally understood.

Patient Services. Patient services is always the most important part of a healthcare business and when things are not being done right with the medical equipment that is delivered, it directly ties to the patient’s satisfaction and outcome quotients. Patient rights and responsibilities must be given to the patient and documented, but this is an area that is often overlooked.

One of the most important areas in patient services is instruction. We evaluate providers not only based on observations of equipment set-ups, but also look at the documentation that the patient must receive.

We also observe occasions where the patient is not asked to do a return demonstration that would have shown that they were confident in operating the equipment. Proper home assessments (grounded electrical outlets, area rugs, etc.) for type of equipment being delivered were also a concern.

Patient follow-ups are not being done as they once were. (Timely follow-ups help prevent costly additional visits and ensure that the patient understands how to operate the device or product. Also showing the patient that you care enough to follow-up can typically generate more referrals.

Equipment Management. Poorly maintained equipment is another major concern (e.g., potential injury from equipment; costly and preventable “switch-outs;” unfavorable outcomes from misuse).

Clinical Respiratory, O&P and Complex Rehab. Common scoring deficiencies with clinical respiratory, O&P and complex rehab are observed in the following areas: lack of policies and procedures for patient assessments and staff qualifications; lack of progress reports to MD, missing AARC guidelines; missing written protocols for ventilator, RAD, IPPB and for apnea monitors.

Orthotics & Prosthetics. O&P Staff training documentation and lack of proper credentials are most often cited. Providers re often unaware of their State requirements for training or needed credentials. Lack of equipment to provide needed services, fabrication or modification.

Other areas of concern include missing diagnostic specific exams, patient instructions and record documentation; non-compliance with MD instructions; and lack of equipment quality assessment prior to delivery.

DME & Supplies (Mail Order). A key problem we see in the mail order sector, include assuring proper fit and suitability for the home. We must know how the provider assures the equipment is appropriate for the home or the shoe or brace is properly fit. In handling returning an item, the provider must accept return of an item if it was not properly assessed for the home/or did not fit appropriately. Some providers have elaborate statements signed by the patients – these do not supersede the Medicare requirements.

Instances of receipt of wrong product can be an issue. Let’s say a diabetes patient received wrong strips. The patient was using another meter with another provider prior to the mail order bid. Know how this is occurring so that the provider is supplying the correct product to the patient.

Also, in having proof of initial contact, we typically ask how the customer came to use the provider. If they do not remember or indicate they were “contacted” by the provider, we will look for this documentation as well. Why is this a concern? Providers are not allowed to solicit Medicare beneficiaries. They need to document how they received the order. Especially when most patients don’t remember!

Physician Orders/Patient Signatures. There are a number of issues concerning physicians. In one instance the physician did not agree that the patient did not need the item (erect aid) and one where the physician did not sign the order provided to our office (shoes). For patient signatures were concerned a key issue is the patient states he did not sign the paperwork in which his name appeared.

Licensing/State Inquiries. The provider needs to contact each State and have documentation on the licensing requirements for each state where they do business. The documentation needs to be written and can include, print screens from the website, state law exemptions, other documentation from the state.

Administration. Common deficiencies to The Compliance Team’s accreditation quality standards included: Incomplete employee files; provider did not collect data on patient satisfaction and complaints; patients were not Informed of charges/co-pay; verification of MD license to validate that a DME order is from a licensed physician who is active, current and in good standing; or lack of Quality Improvement plan and meetings. (These can be combined with staff meetings and an overall business plan.)

The majority of providers are doing what is best for their customers but need to pay attention to these areas that can be problematic during the time between on site visits from their accreditation organization.

This article originally appeared in the August 2015 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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