The Time is Now
It's accreditation renewal time. How can providers smoothly expedite the process and maximize its benefits?
- By David Kopf
- Feb 01, 2018
Like a steadily draining hourglass, the deadline to renew Medicare accreditation is quickly coming up for many HME providers this year. Since 2009, Medicare has required HME providers to obtain accreditation to supply DMEPOS items from the deemed accrediting organizations (AOs), and every three years they must renew.
The last time a large bulk of providers were reaccredited was in 2015, so given accreditation’s three-year renewal cycle, 2018 is another big year. Some providers were able to get out of the process in 2017 to do some advance preparation, but most providers will do their actual renewal work during 2018.
And the process does require time and work from providers to carry it off smoothly and effectively so that they can keep billing Medicare. Moreover, if they do it right, they can gain a strategic edge in their markets (see “Accreditation’s Strategic Value”).
Working With Your AO
The AOs have certainly readied themselves for this year’s accreditation influx.
“Accreditation is a three-year cycle dating back to the original mandated deadline of Sept. 30, 2009,” says Sandra Canally, RN, president of deemed Medicare accrediting organization The Compliance Team. “This year is a cycle year which typically means higher volume for all of the AOs. We are seeing at least double the amount of provider on sites as in the past two years.
“We have planned for the additional volume of on-sites and it is factored into our workflow,” Canally adds. “Over and above the full-time employees we have, because of the additional on-site reviews, we’ve hired some contractors. … I’m sure the other AOs are planning, as well. At this point, we would not have any additional wait times [to renew], or anything like that.”
Claudia Zacharias, MBA, CAE, president and CEO of the Board of Certification/Accreditation (BOC) says her AO is expecting a renewal rush, since it renews on a three-year cycle, as well.
“BOC sees a higher volume of facilities each year as our business is growing overall, and approximately half of our accredited facilities are due to reaccredit this year,” she says. “To avoid delays it’s best to start your reaccreditation process early.
“July, August and September will be the busiest months for reaccreditation,” she adds. “From time to time, BOC offers an incentive for facilities who reaccredit early, and providers who plan ahead and take advantage of this offer will experience no delays whatsoever.
The good news is that there are no major changes or new requirements associated with Medicare accreditation to which HME provider businesses must suddenly conform.
“There have not been any major changes in Medicare accreditation requirements for DMEPOS providers in the past three years,” Zacharias notes. “Providers should focus on any required state licenses, which are subject to change. Providers can reference the National Supplier Clearinghouse (NSC) website at palmettogba.com/nsc for up-to-date requirements.”
To that point, the major changes will be with individual state requirements, according to both Canally and Zacharias. For example, Georgia now has licensure requirements that it didn’t have before, and California and Florida just came out with additional requirements for the accreditors.
“Providers need to be careful with regard to the states because, some of the states with licensure have changed their requirements,” Canally explains. “Such as, needing a brick and mortar location within the state in order to ship product into the state, for instance. So, if they’re doing any kind of mail order into other states outside of where they’re located, they need to continually check that.”
And while the NSC’s supplier licensure directory through Palmetto provides a solid resource, Canally advocates for providers to take things a step further.
“It’s not a bad idea to check the state directly, as well,” she says. “They want to have somebody internally checking out the state.
Where to Start?
As providers approach their renewal, a good place to begin is by 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 procedures might not match up simply due to oversight and other factors. This “renewal season” offers an opportunity to fix that common mistake.
“Everybody should be reviewing their policies on an annual basis just to see if anything needs to be changed,” Canally notes. “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.
“Do ride-alongs with delivery techs to ensure delivery and instruction with the patient is in compliance,” she adds. “Also, depending on equipment ordered, ensure that an assessment is done of the home environment where the equipment will be used.”
In terms of organizing the renewal project, both experts underscore the importance of a team approach. Start by delegating one person to spearhead the effort and then have that individual coordinate with the rest of the staff and report to the business owner or management, Canally suggests.
“Reaccreditation will be an easier process when all staff members are involved and prepared,” she says. “Put somebody in charge. Somebody needs to lead the process.”
“Be certain to have an all-staff training (particularly for new employees who may not have been at the facility three years prior, or have not experienced the survey process) to let employees know what to expect during the reaccreditation process,” Zacharias adds. “It is particularly helpful to create mock scenarios in preparation for the site survey.”
Once it’s time for the site survey, Zacharias suggests planning vacations and staffing levels to ensure key staff are on site when the surveyor arrives. You want to have your expert on-hand if possible.
“If a provider’s business operation allows for one individual to be designated as the person with authority and accountability for the reaccreditation process, that is extremely helpful,” she says. “He or she can be responsible for ensuring preparation is complete, and serve as a go-to resource for the surveyor.”
And really, this goes back to ensuring the whole staff, both new and veteran employees are trained on new policies and procedures, Canally says.
“You want to make sure that the training is up to date; that the processes are the same as what it says in the policy manual,” she explains. “You don’t want to wait until the accreditor comes and says, ‘Well, the training isn’t up to date; this new guy isn’t doing infection control.’”
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. Also, 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.
There are some common renewal mistakes that providers should avoid. For starters, Canally notes that “an area we see a high deficiency rate in” is ensuring that annual training documentation is up to date. Also, she says providers need to make sure that equipment manuals are accessible to employees so that they can ensure they are following manufacturer guidelines.
For Zacharias the most common mistake BOC notices is providers waiting until the last minute.
“Providers should submit their reaccreditation application within a minimum of 30 days prior to their expiration date – ideally, 90 days — in advance,” she explains.
“Also, reaccreditation is a good time to evaluate the service and value of your current accreditor and to investigate alternatives,” Zacharias suggests. “It is a best practice to assure you understand all the fees that might be included in your total cost for accreditation. Many accreditors have annual fees that are not clearly connected to the price, but are part of the business expense for your accreditation.”
Accrediting New Business Lines
Diversification of revenues and mergers and acquisitions activity are two trends that will impact accreditation renewal. How should providers approach reaccreditation if it will include accrediting new business lines either through expansion, or through a purchase?
“If they the provider is adding new business lines, I would strongly suggest they notify their AO ahead of the visit,” she says. “Then I would have them look at what is required by the payer. If it’s a Medicare item, then look at LCD.
“Also, look up any state licensure or certification requirements,” Canally adds. “Make sure the staff is trained on the new product and that the provider has access to the product’s manufacturer agreement.”
In the case of a purchase, Zacharias says everything hinges on how the purchase took place.
“If a purchased business’ tax ID and name changes they cannot transfer accreditation,” she says. “No matter who a provider’s accrediting organization is, they would need to apply for new accreditation.
“If a provider has acquired new facilities that carry product lines their business did not provide before, they would need to ensure the required processes and procedures for each product is in place,” Zacharias adds.
And really, that advice applies throughout the renewal process. As Canally notes, “Bottom line, if the provider has questions about the upcoming renewal, it should reach out to the AO.”
This article originally appeared in the February 2018 issue of HME Business.