Accrediting New Lines of Business
What should providers consider and plan for when it comes to obtaining accreditation for business expansions or acquisitions?
- By David Kopf
- Apr 01, 2018
This year marks a major year for HME provider businesses to renew their Medicare accreditation, but what should they keep in mind when adding a new product category?
Even since Medicare began requirement HME providers billing DMEPOS claims to get special Medicare accreditation in 2009, every three years accrediting organizations see a spike as the majority of the industry hits its renewal requirement.
In fact, the deemed accrediting organizations have been seeing an increase in the number of renewals this time around. Despite what you might have read about the number of providers decreasing, some AOs are even predicting that 2018 could be one of their biggest volumes of renewals.
Moreover, 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.
The First Priority
Getting accreditation for a new category represents an extremely detailed process. Providers going through accreditation for a new category must strive to ensure all the proper documentation and procedural steps are in place for the DME and services they offer, and then undergo site surveys — and possibly have to undergo them again if they are found to need in improvement in some aspects of their business before they can become accredited.
And of course, the provider must continue to work within the accreditation guidelines so that it will maintain that accreditation and be able to easily renew with its accrediting organization. Suffice it to say the provider must do a considerable amount of preparation and groundwork to ensure it can properly support the new category.
With 2018 being such a heavy renewal year, providers adding new lines need to front load that process. So their first step in considering an expansion or a purchase is to notify their accrediting organization.
So start by informing your accrediting organization that your are adding new products that are billable to Medicare to your product line-up. Every accrediting organization has a product code checklist that outline which product categories and codes are covered by a provider’s current accreditation. The accrediting organization will work with a provider to determine if the new products are covered by the provider’s current accreditation, or if a new survey visit is in order.
This initial check is critical because obviously if the provider isn’t accredited for that new line, it likely not get reimbursed for the item. When receiving claims, Medicare performs a cross-reference check to ensure that the provider submitting the claim is accredited for the items being billed.
And that list is regularly updated. Accrediting organizations submit reports weekly to CMS, which includes all the product categories that a provider is accredited for, and if there is any discrepancy in billing, then there is risk of not getting paid. So, before launching into a new business, each provider should be familiar with their accrediting organization’s process in managing the addition of products.
Acquisitions vs. Expansions
When it comes to accreditation, adding a new line is one thing; purchasing a business and possibly integrating that purchase is another. In a merger and acquisition the question of whether a provider should get accredited when purchasing another provider business — even if that business was accredited for Medicare — is not always simple.
In basic terms, accreditation stays with the location, just as a Medicare number does, but this rule doesn’t fit every situation. For instance if the provider were to buy a business and keep it at its existing location, then that Medicare accreditation would stand as is. However, if a provider buys a business and then integrates some of its assets into the company without maintaining the original location, then that will almost definitely require getting reaccredited in that category.
Ultimately, determining accreditation for a purchased business must be addressed on an individual basis, so again, the provider will want to work with its accrediting organization at the outset.
Put the Right Policies and Procedures in Place
Obviously, if a provider is adding a DME item for which it provider is already accredited, not much work needs to be done. But if the provider is adding a new product category that falls outside the scope of the provider’s current accreditation, then the provider will have to work with accrediting organization to put into place all the policies and procedures required to ensure proper provisioning of those items.
The provider will have to work with the accrediting organization to put the proper standards, documentation and operations in place. It will have to ensure paperwork is in order, delivery is timely, patient set-up and education about the item is accurate, and that all the right resources are available.
Have a Team
Remember that accreditation is a time-consuming process and involves considerable detail work. You need to form a team of key staffers who will approach accreditation renewal with the level of intensity your company probably did when first applying.
Once you’ve identified the right people, make sure that not only those staffers, but the entire business understands that the company will be renewing accreditation. Outline why your business is doing this; what any changes will be; 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.
The last thing you want to do is have your accreditation effort get bogged down by decision-by-committee. Identify an expert on your staff who you can trust to lead this effort in a hands-on fashion. You want someone who is ready to work with your accrediting organization to thoroughly understand the needed documentation policies and procedures and will be familiar with how they fit into Medicare accreditation requirements, as well. That leader should also identify and work with key team members in the business who can help implementing company-wide compliance, review workflows, determine how procedures need to change, and implement those changes.
This article originally appeared in the April 2018 issue of HME Business.
David Kopf is the Editor of HME Business.