The deadline for accreditation is out there beyond the fog; it’s out there, but it’s hard to figure out the actual date for implementation. For the 10 statistical Metropolitan Statistical Areas (MSAs), providers need to be ready Jan. 1, 2007 in order to take part in competitive bidding. But those 10 MSAs haven’t been officially determined. When does everyone else need to be prepared? According to Maryanne Popovich, executive director of the Joint Commission on Accreditation of Healthcare Organizations, providers must meet quality standards by Jan. 1, 2010 according to specific legislation in the Medicare Modernization Act of 2003.
In the meantime, accrediting agencies and providers alike are waiting for the Centers for Medicare and Medicaid Services (CMS) to issue the final draft of quality standards. After the standards are issued, CMS will issue rules for the accrediting bodies — an application to the accrediting agencies to apply for Medicare Deemed Status. In essence, CMS has to approve the accrediting bodies before the accrediting bodies have the authority to accredit HMEs. CMS is expected to issue the quality standards by April.
When HME providers are ready to begin the accreditation process, they must first choose a Medicare-approved accrediting agency. There are three well-known accrediting bodies to choose from: the Joint Commission for Accreditation of Healthcare Organizations (JCAHO); the Accreditation Commission for Healthcare (ACHC) and the Community Health Accreditation Program (CHAP). Two additional organizations will likely be approved to conduct surveys for accreditation as well: The Compliance Team and Health Quality Association on Accreditation (HQAA), a spin off group of VGM.
There are four general steps HME providers will have to take to complete the accreditation process:
- Choose an accrediting agency and buy its manual.
- Spend time (most likely months) reviewing the manual and making sure all policies and procedures are up to speed.
- Submit documentation to the accrediting body.
- Wait for an on-site survey.
There’s one catch. The surveys conducted by the accrediting agencies have to be unannounced. Providers will have a year to complete the accreditation process once it begins. While some providers have already started to prepare, others are taking a wait-and-see approach that may result in a backlog when the deadline is finally issued.
The Good News: While accreditation spells more work and more expense for HMEs, the news isn’t all bad. There are many benefits to accreditation including:
- Creates a better business plan and model.
- Develops stronger risk management strategies.
- Reduces incidents.
- Enhances team awareness.
- Develops greater customer trust.
- Establishes a credible framework for reviewing policies and procedures.
- Reduces liability issues.
- Identifies and highlights capabilities and competence.
- Improves employee morale.
- Creates a solid foundation for future growth.
- Improves methods for providing service.
- Improves access and credibility to more payers.
- Improved efficiency.
- Increased professionalism.
- Ability to market accredited status.
Providers can begin preparing by reviewing the following checklist. Provided to Home Health Products by the Accreditation Commission for Health Care (ACHC), it can be used as a guideline to know what accrediting agencies will be looking for when they conduct their surveys. Use this list to prepare for mandatory national accreditation. According to Tom Cesar, president of ACHC, this checklist will also help HMEs determine if your organization is in compliance with applicable local, state, and federal laws and regulations and best business practices.
- Business License is displayed and current.
- HME License is displayed and current.
- Pharmacy License is displayed and current.
- Other License(s) required are displayed: List:
- Copies of all applicable laws and rules are filed or shelved and are available to all staff. These may include Board of Pharmacy, Respiratory Care Board, Board of Nursing, HME Board, Department of Health, etc.
- Policy and Procedure Manuals are available to all staff.
- Office is clean and organized.
- Fire Extinguishers are checked and current.
- Exits are clearly marked. It is recommended that exit signs are the illuminated type.
- Exit plan is displayed in each office, hallway, warehouse, and storage area.
- There is a compliant file/log for storage of all complaints.
- Review of complaint file shows all complaints were managed per company policy.
- There is an incident report file/log for storage of all incidents. Review of incident file shows compliance with company policy.
- Organizational chart is posted and shows all staff.
- Brochures or other marketing material are available for distribution to staff, clients, and the community.
- Employee Handbooks are available to all staff.
- On Call System is effective. Call after hours to check.
- Warehouse is clean and organized.
- Clean and dirty area(s) are marked.
- Maintenance Logs are available. Inspection reveals records are being kept current and up to date on all rental equipment.
- Check for expiration dates on all products having dates. No expired products
- First Aid Kit is available and of appropriate size. Check for any expired products.
- Eyewash station available (check for expiration date).
- Rental equipment is and kept covered with plastic.
- Supply area is organized and clean.
- If oxygen concentrators are provided, calibration records are present for oxygen analyzers. 02 calibration gas tanks with Certificate of Analysis are recommended.
- If oxygen tanks are being filled (liquid or gaseous), check for compliance with FDA requirements.
- Check for a tracking log for oxygen which indicates the client dispensed to, lot #, and expiration date.
- Check for a tracking log that includes any solutions with a lot #, expiration date, and client dispensed to. MSDS files are able with a sheet for all hazardous materials used by the facility.
- A Safety Inspection of the facility has been performed within the past 12 months. Any discrepancies have been corrected.
- There is a recall file/log/notebook in which all recall notices are maintained. All recalls are completed per manufacture guidelines with documentation of the resolution.
- All required posting documents are posted in a prominent area for staff to view. This includes, Family Leave Act, Equal Employment Opportunity Act, OSHA 300A, Job Safety and Health Protection Act, Minimum Wage, Polygraph Protection Act, Blood Borne Regulation and Procedures, and State Poster Requirements. Vans and company vehicles are clean and organized.
- There is a process for separation of clean and dirty equipment in company delivery vehicles.
- Delivery vehicles have Personal Protective Equipment (PPE) available to include eyewash, gloves, mask, HEPA mask, gown(s), germicide, towels, hand sanitizer, and plastic bags.
- MSDS files are available with a sheet for all hazardous materials carried in the delivery vehicles.
- Placarded vehicles have a vehicle safety inspection performed for each day the vehicle is utilized. The inspection of the vehicle shows no safety deficiencies. This is good practice for all delivery vehicles.
- Staff receives annual continuing education that includes at a minimum: Safety, Infection Control, Compliance, Ethics, Cultural Awareness, and Clients Rights and Responsibilities. The education is documented.
- Licensed staff has the state CE requirements documented.
- The Location staff is in compliance with all reporting requirements as required/requested by the QI Coordinator.
(Reprinted with permission from ACHC.)
The Accrediting Agencies
In order to help HMEs select the accrediting body of their choice, the following is a background and overview of each of the accrediting agencies that are likely to have Medicare Deemed Status.
Accreditation Commission for Health Care Inc.
The Accreditation Commission for Health Care Inc. (ACHC) is a national accrediting body established by local home care professionals. Established in 1986, ACHC?s patient-focused, provider-friendly accreditation programs have helped build consumer trust, improve company operations, foster best-clinical practices, generate greater professional self-respect and focus on providing quality patient services. ACHC recently chose to set a higher standard by pursuing a certification to ISO 9001:2000 standards. ACHC offers a Preliminary Evidence Report to direct companies through a self-assessment to highlight strengths and weaknesses.
The Accreditation Commission for Health Care (ACHC)
4700 Falls of Neuse Rd., Suite 280
Raleigh, NC 27609
Community Health Accreditation Program (CHAP)
The Community Health Accreditation Program provides applicants with applicable CHAP standards and Self Studies that allows HMEs to compare their business with CHAP standards such as quality of services and products, available resources, fiscal viability of the organization and the organization’s attention to consumers. According to CHAP, the Self Study is a great launching pad for strategic planning, an incisive management tool and often a boost for staff morale.
Community Health Accreditation Program
1300 19th St. NW, Suite 150
Washington, D.C. 20036
Joint Commission on Accreditation of Healthcare Organizations (JCAHO)
JCAHO has maintained performance-based standards in quality and safety of care since 1951. JCAHO’s Gold Seal of Approval is a distinctive seal and is recognized as a symbol of quality that reflects a commitment to meeting certain performance standards. JCAHO offers Quality Check, a guide that provides the current status of organizations and programs.
Joint Commission on Accreditation of Healthcare Organizations (JCAHO)
One Renaissance Blvd.
Oakbrook Terrace, IL 60181
Healthcare Quality Association on Accreditation
The Healthcare Quality Association on Accreditation offers a new methodology to the accreditation options. The standards were designed and developed with the HME provider in mind; they were not created for another industry and then applied to the HME business. Its process is paperless and interactive using a Web-based design.
Healthcare Quality Association on Accreditation
The Compliance Team
The Compliance Team touts its simplified service and product-line specific accreditation programs for DME and home care. Its Exemplary Provider Accreditation Programs feature the following: understandable plain language standards, consultative assistance, sample policies and forms and a plan — according to The Compliance Team — that can be completed in four months.
The Compliance Team Inc.
531 Cedar Hill Road
How Software Companies Can Help
Many of the HME software companies have tools that can assist providers in meeting the standards of accreditation. Here is what several software companies had to say.
“Accreditation for HME providers is essential today in order to compete effectively in the home care market. From a patient safety standpoint, Fastrack supports accreditation for HME providers specifically in the technology that we utilize and leverage in the development of our software. The ability to accurately track equipment history, maintenance and settings, as well as education for patients and their families is essential to understanding that equipment?s efficiency in the administration of various therapies. In order to adequately understand the life performance of a piece equipment and whether it is safe and effective for patient care, bar coding, wireless inventory tracking and delivery confirmation, providing for real-time information on these pieces of equipment is essential. This is important not only to patient care and safety, but to the health and growth of the business overall.
—Spencer Kay, President
Fastrack Healthcare Systems Inc.
255 Executive Drive
Plainview, NY 11803
“Accreditation helps you better understand and operate your business more efficiently. To that end, accreditation includes helping HME businesses to better manage their inventory and their accounts receivable. Accreditation will also push HME businesses to utilize the HME software for more than just a billing program to get claims paid. HME businesses will want to automate as many features as possible. To that end, QS/1 upgraded our existing HME POS program. It can handle cash, check, credit and debit card sales and automatically relieve their HME inventory quantities. In addition, we added an integrated Document Imaging Module. For less money than the two online document imaging system will charge you in three to five months, you can purchase our integrated Document Imaging Module. This module allows you to scan documents directly to the carrier, doctor, item patient and order/claim records. QS/1 is planning on addressing three other major areas in 2006 to assist HME businesses with increasing their automation. First is the area of a shipping interface with UPS, FedEx, etc. Second is the need to have integrated general ledger, accounts payable and payroll. The third area will deal with improved automation utilizing bar coding for receiving, deliveries and inventory counts utilizing a PDA or possibly even a tablet PC.”
—Jay Williams, National Sales Manager
P.O. Box 6052
Spartanburg, SC 29304
“Continuing Quality Improvement (CQI) is a big part of the accreditation process. RemitDATA provides tools that allow providers to monitor reimbursement performance and implement a continuous quality improvement process around the reimbursement function. The tools allow not only internal benchmarking, but industry benchmarking as well. Additionally, RemitDATA provides productivity tools that allow for process improvement by reducing the time necessary for following up on denials and processing secondary invoices. All of this taken together, empowers a provider to reduce denial rates, reduce total time spent on reimbursement and accelerate cash flow.
— Bently C. Goodwin, CEO & Founder
516 Tennessee St.
Memphis, TN 38103