Spring is here, and so is Medicare accreditation renewal
season. Over the next several months, the industry will see an increased
number of providers starting to work on renewing their accreditation, which
will be due in 2018 for many of them. So now is the time to launch the
accreditation renewal process.
Why? Because accreditation renewal takes work, especially if you are adding
new practices or acquiring other provider businesses. Moreover, there are only
so many accrediting organizations serving the HME industry, which means
it’s in an HME provider’s best interest to start working on the process sooner,
rather than later.
“Next year, 2018, is going to be the next cycle, and we’ll double the amount
of renewals that we will do this year,” says Sandra Canally, RN, president of
deemed Medicare accrediting organization The Compliance Team. “When the
last deadline came we had to pull some companies forward some backward in
order to try to spread it out to make it a little easier.
“Even with that said, we’ve got more this year than last round,” she adds.
“You’ll find that across the board with all the accreditors. If you look at their
accreditation dates on their list of companies accredited you’ll see the bulk
were in 2015, so that obviously means 2018 is going to be the biggest.
So, if providers are going to be visited by their accreditor during the second
part of this year and into 2018, they want to start reviewing their policies, and
making sure that the processes that they have in place match their policies.
In many cases, providers will be in compliance with their AO’s standards, but
their policy might not match what they are doing in terms of process simply
due to oversight and other factors. “Renewal season” is an excellent opportunity
to revisit that common mistake.
“Everybody should be reviewing their policies on an annual basis just to
see if anything needs to be changed,” Canally note. “Especially if they’ve had
new staff come on board older staff that’s been with them a long time maybe
retire or whatever, they want to make sure that they are matching what they
say they do.
“That goes hand in hand with product, because certainly with competitive
bidding some folks have been more creative; they’ve chosen products that were
not subject to bidding,” she continues. “Then they have to make sure that;
their policies, their training, their staff were credential appropriately and this
is a good time looking forward to that renewal with their accreditor to revisit.
Making sure okay in their business plan are they planning on adding any new
product category, so that when the accreditor comes they can be approved for
those products because they’ve put those new things in place.”
And of course this goes double for when a provider has added a new
category or practice, or if it acquired another business.
“They need to be show proof of accreditation for those product categories,”
Canally says. “Remember sometimes people get it mixed up as to okay that
they can still say it’s a non-bid item. They can still bill for items that maybe
we didn’t accredit them for and they are thinking, ‘Oh wow I just got an order
from Dr. Jones; I’ve been after him for a while for referrals. It finally came in
the door and of course we said yes. We made sure we got the equipment, we
filled the order.’ Then they go to bill it and it’s like oops it gets denied, because
it’s not listed on the report that goes to CMS and the NSC showing the product
that they are accredited for. It’s still is very much tied to billing capability.
So there are a lot of reasons for why providers need to get out in front of
accreditation renewal Got it, and what about as far as the actual process of
accreditation or accreditation renewal. Has any of that process changed?
“Nothing has changed from a CMS perspective outside of reporting code
from the AO on the product category sheet,” Canally says. “They’ve summarized
some things there, but in terms of the actual quality standards that all
the AOs need to adhere to nothing has really changed. We continue but that
doesn’t mean I mean obviously it’s still very relatable to the industry. Even if
the industry has changed somewhat it’s still very much a good review of the
processes and practices that they need to have in place with meeting those
quality standards.
“The other thing I’d like to point out is a lot of folks think that okay they
are dropping Medicare, they are getting out of the Medicare program that they
no longer need the accreditation because they associate it with Medicare,”
she says. “Actually that’s not true because most of the state Medicaid, most
of the private insurers if you are in fact doing DME and we’ll just leave it to
DME at this point they look for accreditation too. Often times what we have
is the Blue Cross or an Aetna or one of the big guys, the big payers contact
us ensuring that okay not only are they accredited and they want to know
the dates and expiration but also relating to the product. Even the private
insurers have more or less adapted that way of looking at the provider from a
product category perspective.”
Approach Renewal as a Team
Because most providers want to be ensure their accreditation renewal goes as
smoothly as possible, they should consider a team approach. Many providers
might recall the significant amount time required in order to obtain their
original accreditation. Fortunately renewing accreditation for existing lines is
much simpler, quicker process, and they can apply their experience to ease the
process in getting accreditation for new business lines.
And that’s important because in today’s environment, where providers are
seeking to diversify revenues beyond Medicare, the policies and procedures
that they put in place to adhere to accreditation become a true business advantage. They can use these standards to drive the kind of excellence that
will make them attractive to new types of customers and referral partners.
Let’s examine some key things you’ll want to do to ensure the renewal
process goes smoothly:
The overarching principle in renewing accreditation is that it should be
a company-wide undertaking. All members of the team must be involved
in the process and take ownership in ensuring its success. Because the
accreditation process is time-consuming and incorporates
detailed work, everyone must be involved. Appoint
a project manager and department leaders who can then
work with team members to the task of implementing
the standards throughout the organization. But before
diving in, make certain the organization understands
the imperative to pass renewal. For employees that have
been around the process before, tell them about any
changes. For new employees, review how the process
will work; explain how it might be different from before;
and specify how the process will impact each department
and what will be required of team members in
those departments.
As you renew your accreditation, you will need to have
a mast plan in place. Chances are you might have done
this in earlier instances of getting accredited, but your
entire business should operate under an overarching
outline of all the accreditation standards. These standards
should apply to single process carried out by any
department at any time. Having this master accreditation
provides you with an easy way to review and ensure
compliance at any time. Many accrediting organizations
offer lists that can help you create one that can be tailored
to your business, but it can serve as a good guide to create
this business-wide outline. As you approach renewal,
review your master plan and ensure that is covers all
aspects of your business, old and new.
For any new employees who have not experienced
accreditation, or if you are adding new lines of business
that will require additional accreditation, or if your
accreditation organization has expanded its standards
for your existing accreditation, your team will need
to be ready. They must be trained in new policies and
procedures being put in place. This could even entail
the addition of new credentials on your staff, so you will
need to ensure your staff has the necessary certifications
and licensure, and that those credentials are up to date
and have sufficient CEUs. Moreover, if you are expanding
geographically, then the staff at new locations will need
to accredited, and that could entail unique requirements
for those employees. For instance, different states have
different requirements regarding required certification or
licensure for providing different types of care of service.
CMS’s ramping up of claims audits, as well as pressures
such as the face-to-face requirement mean that
providers need to have their documentation ducks in a
row. And, accrediting organizations will be monitoring
this with a careful eye in order to ensure your business
is safe from the threat of pre- and post-payment
audits. The risk is simply too serious and the right
documentation procedures must be in place. So, as a
special part of your accreditation renewal, you must
highlight the fact that all departments need to adhere to
their required documentation procedures through the
entire claims and care process — from having the right
documentation from physicians on claims to patient
signatures on delivery tickets.
Perhaps the culmination of the accreditation renewal process is the site
survey. Like a pop quiz, you might not know when it is going to happen, but
you can at least be prepared. If the accreditation standards outlined by your
accrediting organization are indeed part of you business’s regular operating
procedure and are second nature to every employee, then you should feel
confident you’ll pass with flying colors.