Accreditation
The deadline has arrived: Now What?
What are the full implications for the Sept. 30 cut-off, and what can providers do if they are going to miss it?
- By Joseph Duffy
- Sep 10, 2009
For HME providers who have yet to apply for accreditation, the accreditation countdown clock is now eerily quiet. Instead of facing the frantic conclusion to onerous preparation and the anticipated site visit, they must face the sobering realization that if they are not now in the accreditation pipeline, this is the calm before a real and potentially disastrous storm.
Without some sort of stay of execution from Congress — deemed wishful thinking by the experts interviewed for this story — these non-accredited HME providers cannot bill CMS for Medicare funding after Sept. 30. In addition, they must now compete with accredited providers, whose new status touts their better business practices. One must ask: What are these non-accredited providers going to do? And more importantly, how are they going to survive?
Why avoid the inevitable?
Our industry experts who contributed to this article could only speculate as to what percentage of providers applied for accreditation versus abstaining from the process. Sandra Canally, RN, president of The Compliance Team, an accrediting body headquartered in Pennsylvania, says that the bulk of providers has come forward and has applied for accreditation, leaving about 10 percent of providers who are at this time not going to make the deadline.
“The DME industry is largely comprised of small, independent businesses, some of which are not actively involved in the industry,” says Julie Piriano, PT, ATP, director of rehab industry affairs for Pride Mobility/Quantum Rehab. “While it may seem unthinkable, some of these companies may not have been aware of the CMS deadline or the requirement to be accredited by Sept. 30. Others within the industry may be waiting for a last-minute reprieve of the requirement in the hopes that their business will be exempt or the accreditation deadline will be pushed back again as we have seen in the past.
“The problem with this theory is that the Sept. 30 deadline is a Congressional mandate, not a CMS deadline that can be changed by the Secretary of HHS,” she continues. “The providers who have elected not to comply with the accreditation deadline have most likely made a business decision to no longer participate in the Medicare program. While the decision to forego accreditation may work out for them in the short term it could have negative long-term consequences should other payors mandate accreditation, as well.”
Roberta Domos, RRT, owner and president of Domos Home Medical Equipment Consulting Group, suggests the only way there could possibly be a deadline change is if the collective accrediting bodies were to make the plea directly to Medicare, with the reason being that they cannot complete all the surveys they have scheduled by the deadline. It is unclear how many providers have applied this year but will receive site visits after the Sept. 30 deadline.
The economy certainly hasn’t helped providers. John Allman of John Allman Consulting, located in Paso Robles, Calif., says, “For whatever reason, whether it be cash flow or being cash-strapped, if providers don’t have the funds to become accredited but are Medicare dependent, they are in a vicious circle. Not getting accredited because they can’t afford it is the only ‘good’ reason I can see a provider not becoming accredited.”
According to our industry experts, the cost of accreditation varies due to company size, number of locations and affiliate locations, and whether the provider is a pharmacy or a full-service HME organization.
All things considered, the cost for CMS accreditation is between $1,500 and $5,000, not including outside resources such as consultants and policy manuals. However, if this is stopping providers from going forward, some accrediting bodies are offering payment plans.
At the end of the day, says Laraine M. Forry, owner of LMF consulting service, “There are still providers that just don’t understand the consequences.”
Truth or consequences?
If Forry is right and providers don’t understand what awaits them come Oct. 1, there needs to be a mass intervention.
Missing the deadline equates to an interruption in Medicare billing until those providers meet the mandatory accreditation standards and complete the accreditation site survey process.
Mary Nicholas, Executive director of the Healthcare Quality Association on Accreditation, says missing the deadline will add “additional stress and strain on managing the in-activation of the billing number, getting through their accreditation, submitting a request for re-activation of their number, and the days-waiting in between. It will mean no reimbursement for services or equipment. It could mean the beginning of the end of many businesses.”
“Hopefully those providers who miss the deadline have an alternate business plan in mind, but for those providers that did not intend to miss the deadline it could have devastating consequences for their business,” Domos says.
And one of the biggest consequences of missing accreditation that Forry feels has been overlooked over the past two years of discussion is who will be servicing the patients once the provider loses their provider number by either voluntary termination or when their provider number is revoked?
Plan B?
Domos hints in her quote above that some of these providers might have decided that an alternative plan was strong enough to counter the ill-effects of non-accreditation. Nicholas says that according to HQAA data, approximately 15 percent to 20 percent of providers do just a little or a minor portion of their business with Medicare.
“Providers certainly could put all of their ‘ducks’ in the third-party payer systems, but so many of those also require accreditation,” said Nicholas. “It’s inevitable no matter which way you look. I used to say that I was the last person to own a DVD player and then I’d laugh. It won’t be funny to say you’re the last one to become accredited. Customers are getting wiser to looking for and expecting the quality that comes with subscribing to some sort of external compliance or regulating body.”
Domos points out that there are a substantial number of providers who have weaned themselves off Medicare over the course of the last decade, choosing instead to focus on retail business, or other insurance payors such as Medicaid and private and third-party payors. “Unfortunately, though, more and more private and third-party insurance payors are closing their networks to new or independent DME providers, choosing instead to enter into exclusive contracts with national DME providers or the independent providers that have legacy contracts with them,” she said. “In some parts of the country Medicare is the last bastion of patient freedom of choice when it comes to DME providers.”
While accreditation is a requirement for Medicare funding as of Sept. 30 it is also a statement to the public at large that a company has successfully passed an independent review of the processes, procedures and practices in the provision of durable medical equipment and the continuum of medical care, Piriano says.
“While some providers may be okay with not being accredited it will become increasingly difficult to convince consumers and referral sources that your business is equivalent to the other businesses in your marketplace without it,” she says. “Businesses that may be part of a closed loop referral and payment system and do not rely or participate in the Medicare program may not find an accreditation advantage; however, this scenario is an exception to the rule.
“In the short term there may be a way to thrive in certain market places and under certain conditions; however, it is not likely to be a successful business plan in the long run,” she continues. “The industry has become accustomed to the fact that once Medicare makes a decision as to a direction they are taking most if not all other payors eventually follow suit with that direction; therefore, a long-range plan that includes accreditation is much more likely to lead to a successful business plan.
“While there are providers who do not rely or bill the Medicare program it can be potentially short sighted to view accreditation as a ‘Medicare only’ program.”
What to do?
If you are a HME provider who depends on Medicare and will not be accredited by Sept. 30, there are options, although few in number. Here is a summary of advice from industry experts who feel your pain and understand the dire consequences you might face come Oct. 1 if you are not accredited.
• Get accredited. You might not make the Sept. 30 deadline, but that doesn’t mean accreditation should be shunned. Providers who applied in January saw an average four-month to six-month wait before getting a site visit. According to Canally, that timetable was thrown out the window because of a large number of providers who missed that deadline and have applied as late as July, and the announcement that subcontractors would also need to be accredited by Sept. 30.
Providers need to be highly committed to achieving accreditation and getting the necessary preparation completed to have a successful site visit. You’re already going to lose your Medicare funding after Sept. 30, so make the accreditation process as smooth as possible for you and your employees to regain that funding as quickly as possible.
Interview and choose wisely an accrediting body that best meets your needs and can work with you to get a site evaluation sooner rather than later. (See the sidebar for a list of accreditation organizations.) Also, providers in this situation should ask accrediting bodies what their current timeframe is to complete the survey process before committing to one accrediting body over another.
• Monitor the industry for news. Although most industry experts feel the deadline will not change, pay close attention to any announcements or guidelines offered by the NSC or CMS. Consider setting up Google alerts, which are sent directly to your email, to receive any breaking accreditation information that could help you. Visit www.google.com/alerts for more information.
• Voluntarily suspend your Medicare supplier number. Suspending your Medicare supplier number if you will not make the deadline was high on our experts’ list of things to do. Notify CMS that you would like to voluntarily suspend your Medicare supplier number until such time as you have completed the accreditation process for the product lines you intend to continue providing to Medicare beneficiaries. If you let your number become revoked for failing to get accredited, it will be harder for you to reinstate your number than if you voluntarily pulled it. “If your number is revoked,” says Canally, “you could lose privileges for up to a year.”
• Rethink cash sales. If you have a retail location, look at diversifying and boosting cash sales. Consider products and product mixes that you can provide without being in a Medicare population, such as pediatrics and chronic illness products not covered by Medicare. To providers not seeking accreditation, Allman suggests that you “think outside the box, now that you have to live there.”
• Consider selling the business. If you are not going to become accredited and losing your Medicare funding can cause your business to fall into irreparable dire straits, then another option is selling your business.
Additional challenges to accreditation deadlines
In June of this year, under The Medicare Improvements for Patients and Providers Act (MIPPA), subcontractors learned that accreditation wasn’t just for providers — subcontractors who provide delivery, instruction, repair and/or maintenance to DMEPOS items on behalf of the Medicare supplier were now under the same Sept. 30 accreditation deadline.
In addition, providers currently undergoing the accreditation process will not be able to receive accreditation certification until their subcontractors receive accreditation for those services that they provide, said Canally. The reality is: Providers might have to sever ties with subcontractors if they don’t get accredited. “This is the biggest concern going in the industry,” she says.
“This has created a new challenge in the accreditation process as the services and subcontracting entities that provide them are not subject to all of the DMEPOS quality standards and there is no succinct direction being provided by CMS with regard to the requirements necessary to satisfy accreditation compliance for the subcontractors who are providing these services,” Piriano says. “And Pharmacies are required to obtain accreditation like any Medicare DMEPOS supplier.”
According to Domos, many pharmacies will no longer be able to provide even a minimal line of DME products once the deadline passes unless congress passes a last-minute exemption for them.
“Many pharmacy owners have simply decided it would not be worth the time and expense it would take to go through the process, or were hoping that they received a last-minute reprieve,” Domos says. “Subcontractors involved in direct patient care should be following the accreditation standards in order to provide services to accredited DME providers. And they should obtain their own accreditation in the near future if they plan to subcontract for DME providers that will be bidding in the CMS competitive bid program.”
A world without Medicare
Allman says, there is a world without Medicare, but if you’re not getting accredited and you built your business around Medicare funding, business is going to be very difficult. If you’re not in the accreditation pipeline, there is no fast-track to accreditation. Therefore, your recipe for success will rely on innovation and diversification that results in your replacing lost revenue.