Accreditation renewal is nothing to worry about if you've been sticking to a plan.
- By Holly J. Wagner
- Apr 01, 2018
Early in The Hitchhiker’s Guide to the Galaxy, our hero Arthur Dent finds himself on a ship hurtling through space, with the earth collapsing behind him. He finds a book with two words on the cover: DON’T PANIC!
In the DME pharmacy world, you are Arthur and your accreditation organization (AO) is your guide to the accreditation galaxy. And their message for what is expected to be a very busy renewal year is the same: Don’t Panic.
That’s because accreditation is meant to introduce and maintain what are basically industry best practices within a pharmacy and/or DME business. If you are already accredited, chances are you are already doing a lot of them and accreditation is more about verifying standards than doing anything new.
“It [accreditation] standardizes their policies. If they follow the standards as a blueprint for their business, it makes them better able to run their businesses. We have universal standards that apply across all the modalities,” says Sandra Canally, RN, president of deemed Medicare accrediting organization The Compliance Team.
A small pharmacy that has been keeping up with standards since its last accreditation should expect to spend about an hour a month sticking to them, says Timothy Safley, director of DME Pharmacy & Sleep at ACHC. “That’s all that’s invested. It’s very little time and investment to keep up with the quality standards…. It’s best practices, but the reality is that it makes sure you are meeting the Medicare standards.”
That’s not to say there is no time and effort involved, especially if you need to play catch-up, but if you’ve been maintaining standards since your last accreditation, renewal should be much smoother. If you’ve fallen behind, AOs have checklists and compliance guides to help you get on track, and in the worst case they can help you submit a compliance action plan to get to renewal.
PLAN AND SCHEDULE AHEAD
When in 2009 Medicare began requiring that HME providers get accreditation from the deemed AOs to bill for DMEPOS items, it triggered a surge that repeats itself every three years with renewals. The AOs are staffing up to meet demand, but they still advise booking as soon as you’re ready, to get on the inspection schedule as early as possible.
“These pharmacies need to apply early. You certainly don’t want your accreditation to lapse,” Safley says.
Scheduling early is important not only because it is busy year in the renewal cycle, but because AOs schedule site visits regionally, so the surveyors can visit many clients in a given area on one trip. That takes a fair bit of planning for the AO.
“It takes up to 90 days, depending on how ready you are and how quickly we get out there,” says Wendy Miller, BOC chief credentialing officer. “The busiest time will be July through September.” BOC sends its clients early reminders and incentives to try to get people to reaccredit early, she added.
“Normally, I have seen people get it done within 30 to 60 days,” she continued. “Once the request comes in it takes about a week to assign it to a site surveyor, and the surveyor is to complete that between two to three weeks. Then they have a week to turn in a report.” The key to moving the process along is for the provider to be ready.
“What I advise pharmacies that are up for renewal is one, look at their policies, making sure that their processes match their policies,” Canally says. “We’re looking at their whole business. Our approach is operational. Who the owners are, what their business policies are, what their daily workflow is, what kind of training they do.”
STAFF PREP AND PARTICIPATION
AO representatives stress that it’s important to designate a point person to prepare for site visits, and hold staff meetings so new and longtime employees are up to speed on what is expected.
“They should have a staff meeting and let them know what is going to happen. That the surveyor is going to come on site, and to please answer questions as best you can,” Miller says. She recommended that the point person be someone in your organization who is empowered to show employee and business records.
In advance of site visits, management and the point person can ask their AOs for resources. You wouldn’t take an SAT without boning up, right?
“A lot of accreditors have workbooks or workshops to make sure the clients have everything in line. There are workbooks and consultants,” Safely says. “If you follow all of that, you are going to breeze through accreditation. Reach out to your accreditor. Make sure they have all the tools to help you.”
It’s important to know your business and your clientele, so you get only the accreditations you really need, says. “In our application we include all the types of products that they can get accredited for,” Canally says. “Sometimes they think they should check all the boxes, when the reality is that a small retail pharmacy is not going to do ventilators.”
The Compliance Team can provide help with those decisions. “Anybody that signs up in our program is assigned an advisor and scheduled for one-on-one videoconference,” she says. “It explains the standard we are holding them accountable to.” Clients get self-assessment checklists for each section of the standards, so they can gauge their progress on what they are doing to prepare.
“We send them a form that says ‘on-site ready.’ Then we assign somebody else to go on-site to verify and validate that they actually meet the standards,” Canally says. “A typical on-site with an accreditor would be looking at their policies and procedures and looking at their day-to-day operations for how they execute their policies and procedures.”
WHAT IF THE DOG ATE YOUR HOMEWORK?
Many small businesses are so busy, it’s easy to focus on customers and filling orders and let some of the documentation or meetings slide. “You are not going to fail outright because of that. You would submit a compliance action plan,” Miller says, noting the AO should help you do that. Some of the most common issues are around client surveys, logging, billing and encoding errors.
If you fear you have gotten behind on your paperwork, get busy with your documentation, Canally recommends. “You should be following Rxthose checklists with the accreditor standards. That will walk you through what type of documentation you should be looking at,” she says. “It’s just making sure that they are keeping up with their performance management policies. That is the area where some of them fail behind.”
If your surveyor visit turns up a problem, the AO will send a deficiency letter detailing steps to return to compliance, Miller says. Most compliance shortcomings are related to documentation, because people forget, or just get busy and things can fall through the cracks. “Get your logs up to date and adhere to your policy of having quarterly or biannual meetings with your staff,” she says.
IT’S WORTH IT IN THE END
After all the time and expense, accreditation and renewal are worthwhile. Accreditation ensures you can continue to bill Medicare for many DMEPOS items, and many private insurers as well.
“When an accreditor walks in the door, they already know the rules and regulations and they are helping the pharmacy to prepare for the CMS visit,” Safley says.
He notes Medicare Part B includes exemptions for pharmacies that have been open for less than five years, or if DMEPOS is less than 5 percent of their business. “They have to follow the same rules and procedures, but they don’t need [DMEPOS] accreditation,” he says. For more information on exemptions, visit go.cms.gov/2DgmfJx for a downloadable PDF.
But it may still matter to private insurance companies if you plan to bill them. “Now the private commercial insurers follow Medicare. So we will get calls from [Blue Cross Blue Shield] asking us about a specific provider -- because we have a list on our website of who we have accredited -- asking what they are accredited for and when that expires.”
Accreditation can also help boost your credibility with local physical therapy, post-acute and geriatric care facilities and providers who can provide referrals. Case managers, discharge managers, therapy providers, long-term care and assisted living facilities are all likely to recognize and value accreditation.
“It is good for your referral to know you are meeting standards above and beyond the state requirements,” Miller says. “Patients and beneficiaries can be assured of good quality patient care.”
Safely agreed. “I think the main thing when we talk about this is, it’s all about the patient care. It is a verification that the pharmacies are doing everything that they can do to provide patients the best services they can give.”
A NOTE ON COST: Expect to spend about $3,000 to $4,500 for accreditation, depending on what accreditations you need and the terms of the AO you choose. Typically with most of the accreditors, in renewal the cost will go down. For most pharmacies, the benefits in billing and streamlining your business are well worth the investment.
This article originally appeared in the DME Pharmacy April 2018 issue of HME Business.