Скачать презентацию It s 2007 Mandatory Accreditation is Here Are You Скачать презентацию It s 2007 Mandatory Accreditation is Here Are You

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It’s 2007! Mandatory Accreditation is Here! Are You Prepared? Wednesday, April 25, 2007 Med. It’s 2007! Mandatory Accreditation is Here! Are You Prepared? Wednesday, April 25, 2007 Med. Trade Spring Mary Ellen Conway President

Overview • What is the accreditation requirement? • Who are the recognized accreditation providers? Overview • What is the accreditation requirement? • Who are the recognized accreditation providers? • When do YOU need to be ready? • First 10 MSA’s, Next 80 • First Ten Products for Bidding • Final Quality Standards • Inconspicuous Items” • Concerns 2

Overview Continued • Clarifications • Every Organization’s “Must Haves” • Accreditation choices- tips to Overview Continued • Clarifications • Every Organization’s “Must Haves” • Accreditation choices- tips to use in your selection • How do you get started? • Review of the Final Quality Standards • Review of the recognized Accreditation Providers • Ten things you can do now to be ready 3

What is the Accreditation Requirement? • The Medicare Modernization Act of 2003 (MMA ’ What is the Accreditation Requirement? • The Medicare Modernization Act of 2003 (MMA ’ 03) states that ALL DME Providers billing Medicare for identified Part B products must be accredited by 2007 --- this will be enforced initially through the Competitive Bidding Requirement • January 26 announcement rescinded BUT TODAY? ? ? 4

The “Dominos” • CMS is enforcing the law that requires competitive bidding in 2007 The “Dominos” • CMS is enforcing the law that requires competitive bidding in 2007 (Now April 2008) • Only accredited organizations can submit a bid and “compete” in the bidding process • Accreditation must be by “recognized” accreditors • Provider must comply with Final Quality Standards (Released 8 -14 -06) 5

Who Are the Recognized Accreditors? …And then there were ten… Changed January 2007 JCAHO Who Are the Recognized Accreditors? …And then there were ten… Changed January 2007 JCAHO NB of A for Orthotic Suppliers CHAP CARF HQAA BOC ACHC NABP ABC of O&P The Compliance Team 6

When Does Competitive Bidding Begin and Where? • Competitive bidding “rolls out” in 2007 When Does Competitive Bidding Begin and Where? • Competitive bidding “rolls out” in 2007 in 10 Metropolitan Statistical Areas (MSA’s) and in 80 in 2009 – Excludes New York, Chicago and Los Angeles in 2007 • Only accredited providers can participate in competitive bidding 7

The First 10 MSA’s Temporarily Listed on CMS Website at 9: 00 AM 3/30/07 The First 10 MSA’s Temporarily Listed on CMS Website at 9: 00 AM 3/30/07 Charlotte-Gastonia-Concord: NC-SC Cincinnati-Middletown, OH-KY-IN Cleveland-Elyria-Mentor, OH Dallas-FT Worth-Arlington, TX Kansas City, KS-MO Miami, Ft Lauderdale, Miami Beach, FL Riverside, San Bernadino, Ontario, CA Orlando, Kissimmee, FL Pittsburgh, PA San Juan, Caguas, Guaynabo, Puerto Rico 8

The Top 20 MSA’s Were Charlotte Miami Riverside, CA Phoenix Cincinnati Houston Dallas Orlando The Top 20 MSA’s Were Charlotte Miami Riverside, CA Phoenix Cincinnati Houston Dallas Orlando Tampa Cleveland Boston Kansas City, MO and KS Pittsburgh San Francisco Atlanta San Juan St. Louis Detroit Seattle Philadelphia 9

Next 80 Largest MSA’s Los Angeles Washington, DC Nassua/Suffolk Portland, OR Ft Lauderdale Columbus, Next 80 Largest MSA’s Los Angeles Washington, DC Nassua/Suffolk Portland, OR Ft Lauderdale Columbus, OH Salk Lake City Providence. RI Middlesex/Somerset Jacksonville New York St Louis, MO/IL Oakland, CA Ft Worth, TX Indianapolis Milwaukee Greensboro, NC Raleigh/Durham Memphis Rochester, NY Chicago Richmond, VA Denver Las Vegas San Antonio Bergen, NJ Austin Hartford W Palm/Boca Grand Rapids San Diego Louisville Newark, NJ San Jose, CA Virginia Beach New Orleans Nashville Buffalo Monmouth Fresno 10

Next 80 Largest MSA’s Con’t Oklahoma City Greenville, SC Albany Tucson Syracuse Omaha Knoxville Next 80 Largest MSA’s Con’t Oklahoma City Greenville, SC Albany Tucson Syracuse Omaha Knoxville El Paso Allentown, PA Harrisburg Jersey City Baton Rouge Little Rock Ann Arbor Charleston New Haven, CT Mc. Allen/Edinburg, TX Dayton, OH Honolulu Tulsa Ventura, CA Albuquerque Akron Bakersfield Gary, IN Scranton Toledo, OH Youngstown, OH Springfield, MA Stockton, CA Wichita Mobile, AL Columbia, SC Sarasota/Bradenton 11

In order to bid in the first round • You must be accredited by In order to bid in the first round • You must be accredited by August 31 st! • Means: – Survey scheduled by early- mid July – Work through all process through May/June NOT MUCH TIME! 12

The MSA Uses US Census Data – Applies to defined Zip Codes where the The MSA Uses US Census Data – Applies to defined Zip Codes where the beneficiary resides, not where the provider is located – Was excluding Mail Order in the First Round, but now includes only diabetic supplies via mail order 13

When Do You Need to Be Ready? • If you provide any of the When Do You Need to Be Ready? • If you provide any of the identified products or services to Medicare beneficiaries in any of the first 10 defined areas and wish to continue, you will be required to bid. • In order to bid, you will need to be accredited. • If you provide products and services to Medicare beneficiaries in such areas as who are NOT in the first defined service areas, you may be required to participate in Competitive Bidding in 2009 (80 MSA’s identified for Competitive Bidding in 2009) • All mail order starts in 2009 in the First 10 MSA’s and the subsequent 70. • All others are required to be accredited (whether or not there is Competitive Bidding in your service area) as early as 2009 -2010— TODAY”S ANNOUNCEMENT 14

What if You Provide Products and Services in Rural Areas Only? • You may What if You Provide Products and Services in Rural Areas Only? • You may never have to participate in Competitive Bidding • You will get a rate adjustment as CMS will begin to reimburse providers the rates paid in the closest MSA’s • You must be accredited by some date- no finite date released yet. – CMS advisory released Friday, January 26 (CR 5415 Transmittal 188) rescinded 15

Current Legislative Activity • Tanner Hobson (formerly Hobson Tanner) www. aahomecare. org Advocacy Updates Current Legislative Activity • Tanner Hobson (formerly Hobson Tanner) www. aahomecare. org Advocacy Updates Also: Price Repeal of 36 mo Oxygen Cap (H. R. 621) 16

Final Product Categories 1. Oxygen Supplies and Equipment 2. Standard Power Wheelchairs, Scooters and Final Product Categories 1. Oxygen Supplies and Equipment 2. Standard Power Wheelchairs, Scooters and Related Accessories 3. Complex Rehab Power Chairs and Related Accessories 4. Mail Order Diabetic Supplies 5. Enteral Nutrients, Equipment and Supplies 6. CPAP, RAD’s and Related Supplies and Accessories 7. Hospital Beds and Related Accessories 8. Negative Pressure Wound Therapy Pumps and Related Supplies and Accessories 9. Walkers and Related Accessories 10. Support Surfaces (Groups 2 and 3 mattresses and overlays) in Miami and San Juan only 17

Product Selection • CMS selected products for CB based on: – High cost – Product Selection • CMS selected products for CB based on: – High cost – High-volume – Greatest potential for savings 18

Final Quality Standards • Were released on 8 -14 -06 !!! • 14 pages—as Final Quality Standards • Were released on 8 -14 -06 !!! • 14 pages—as compared to 104 in September 2005 • VERY MINIMAL compared to proposed standardsbut don’t be fooled! Found on the CMS website at: (http: //www. ) cms. hhs. gov/Competitive. Acqfor. DMEPOS/04_New_Quality_Standards. asp • Compliance with these standards will be enforced through the accreditation provider you select 19

Final Supplier Quality Standards 2 Sections First Section: Business Services – Administration – Financial Final Supplier Quality Standards 2 Sections First Section: Business Services – Administration – Financial Management – Human Resource Management – Consumer Services – Performance Management – Product Safety – Information Management 20

Final Supplier Quality Standards Second Section: General Product Specific Service Standards • Preparation – Final Supplier Quality Standards Second Section: General Product Specific Service Standards • Preparation – Intake – Beneficiary Record • Delivery and Set-Up • Training/Instruction to Beneficiary and Caregiver • Follow-up 21

Final Supplier Quality Standards Appendix A- C A: Respiratory Equipment, Supplies and Services – Final Supplier Quality Standards Appendix A- C A: Respiratory Equipment, Supplies and Services – Oxygen concentrators, reservoirs, high pressure cylinders, oxygen accessories and supplies, oxygen conserving devices – Home invasive mechanical ventilators – CPAP Devices – Respiratory Assist Devices – IPPPB Devices – Nebulizers 22

Final Supplier Quality Standards Appendix A- C B: Manual Wheelchairs, Power Mobility Devices, Complex Final Supplier Quality Standards Appendix A- C B: Manual Wheelchairs, Power Mobility Devices, Complex Rehab and Assistive Technology Key Issues in Complex Rehab and Assistive Technology: – Check items listed – Employ at least one qualified RTS per location – Provide appropriate equipment for trial – Provide private, clean and safe rooms appropriate for fitting and evaluation – Maintain a repair shop located in the facility 23

Final Supplier Quality Standards Appendix A- C C: Custom Fabricated, Custom Fitted, Custom-made Orthotics, Final Supplier Quality Standards Appendix A- C C: Custom Fabricated, Custom Fitted, Custom-made Orthotics, Prosthetic Devices, Somatic, Ocular and Facial Prosthetics and Therapeutic Shoes and Inserts • Not off-the-shelf items 24

Final Standards Administrative 1. Obtains and supplies appropriate quality equipment, items and services 2. Final Standards Administrative 1. Obtains and supplies appropriate quality equipment, items and services 2. Have a physical location and display all licenses, certificates and permits 3. FDA approved items and obtain copies of features, warranties and instructions 4. Comply with Medicare policies (coverage, claims processing, payment policies and disclosure of ownership) Example: Disbarment List www. oig. hhs. gov/fraud/exclusions. html 5. Implement business practices to prevent and control fraud, waste and abuse 6. Use procedures that articulate standards of conduct that ensure compliance with appl. laws and regs. 7. Designate leader(s) responsible for compliance issues 25

Final Standards Financial Management 1. Implement financial management practices that ensure accurate accounting and Final Standards Financial Management 1. Implement financial management practices that ensure accurate accounting and billing. 2. Accurate, complete and current financial records 3. Cash or accrual based accounting 4. Link equipment to client 5. Manage revenues and expenses on an ongoing basis: • Reconcile charges with invoices, receipts and deposits • Operating budget • Mechanism to track actual revenues and expenses 26

Final Standards Human Resource Management Implement policies on: Specific qualifications Training Experience Continuing education Final Standards Human Resource Management Implement policies on: Specific qualifications Training Experience Continuing education requirements Technical personnel: Competent Licensed, certified or registered (and current copies on file) 27

Final Standards Consumer Services Provide clear instructions on use, maintenance and potential hazards of Final Standards Consumer Services Provide clear instructions on use, maintenance and potential hazards of item(s) Provide expected time frame for receipt of delivered item(s) Verify item/service was received Provide contact information and options for rental or purchase Provide information and telephone numbers for customer assistance: Regular business hours, after hours, repair, emergencies 28

Final Standards Performance Management Implement performance management plan that measures outcomes of customer service, Final Standards Performance Management Implement performance management plan that measures outcomes of customer service, billing practices and adverse events. At a minimum, measure: – Beneficiary satisfaction and complaints – Timeliness of response to questions, problems and concerns – Impact of business practices on adequacy of beneficiary access to items, services, information – Frequency of billing/coding errors – Adverse events 29

Final Standards Product Safety Equipment management program that promotes the safe use of equipment Final Standards Product Safety Equipment management program that promotes the safe use of equipment and minimizes safety risks and hazards including: 1. Plan for identifying, monitoring and reporting failures, repair and preventive maintenance 2. Investigate any accident or injury (within 72 hours or 24 hours if results in hospitalization or death) 3. Contingency plan for response to emergencies and disasters 30

Final Standards Information Management Maintain accurate, pertinent, accessible, confidential and secure records in accordance Final Standards Information Management Maintain accurate, pertinent, accessible, confidential and secure records in accordance with HIPAA and any state standards 31

Other “Inconspicuous” Items Health screenings, drug testing and criminal background checks • According to Other “Inconspicuous” Items Health screenings, drug testing and criminal background checks • According to state requirements Infection Control • No specific requirement, but certainly required by accreditors Mail Order • “Verify” training and instructions at the time of initial mail order delivery 32

Many Concerns • This is not the program that was used in the demonstration Many Concerns • This is not the program that was used in the demonstration project that Congress had in mind when they were voting on this in 2003 • CMS has been VERY far behind in their timeline • They are basing components of the program on information that may be inadequate – Focus groups (44 participants in 22 states) 33

Clarifications • Final Rule was released on April 2, 2007 • Networks-TODAY • Use Clarifications • Final Rule was released on April 2, 2007 • Networks-TODAY • Use of American Association for Respiratory Care Practice Guidelines (last updated in 1992) 34

Every Organization’s “Must Haves” • Policy and Procedure Manual • Complete and Accurate Paperwork Every Organization’s “Must Haves” • Policy and Procedure Manual • Complete and Accurate Paperwork for Patients • Updated/Complete Educational Materials • Competency Program • Complete PI Program 35

Must Have # 1: Complete Policy and Procedure Manual • Must meet the needs Must Have # 1: Complete Policy and Procedure Manual • Must meet the needs and requirements of the accreditation provider you select • Not worth trying to create on your own at this point 36

Must Have # 2: Complete Paperwork for Patients Such as: Consent for Treatment/Services AOB Must Have # 2: Complete Paperwork for Patients Such as: Consent for Treatment/Services AOB Third Party Review HIPAA Information Disaster/Emergency Preparedness How to Reach the Office (Hours) 37

Must Have # 3: Updated Educational Materials Many of the requirements of the standards Must Have # 3: Updated Educational Materials Many of the requirements of the standards speak directly to the educational materials you provide to your patients 38

Must Have # 4: Competency Program • Review the requirements of your accreditor and Must Have # 4: Competency Program • Review the requirements of your accreditor and be sure you meet them • Generally only technical staff are required to have competency evaluated • Can be written (testing) but must be observed for technical staff 39

Must Have # 5 Performance Management 1. Beneficiary satisfaction surveys 2. Patient complaint log Must Have # 5 Performance Management 1. Beneficiary satisfaction surveys 2. Patient complaint log 3. After hours (on call) log to prove timeliness of response to questions, problems and concerns 4. Log that documents frequency of billing and/or coding errors 5. Log documenting adverse events (as defined by your P & P manual) Most accrediting organizations require at least three months of surveys collected and summarized with plans for improvement or you will have to provide written follow-up and possible a re-visit 40

How Do I Get Started? ? ? How Do I Get Started? ? ?

Tips to Use in Choosing Your Accreditor • CMS is not your only payer! Tips to Use in Choosing Your Accreditor • CMS is not your only payer! – Payer or state licensure requirements to be accredited • What is the accreditor’s schedule and what are the requirements for in-between? – Ex: triennial and 18 month written update • Fees paid vs. administrative costs • Network participation • Other services (infusion, home health) • Process (electronic vs. paper) • Interview/discussions with accrediting organization— your perceptions • Your peer’s experience 42

The Current Ten Recognized Accreditors The Current Ten Recognized Accreditors

Comparing “Apples-to-Apples” Product Category Definitions DME Limited Mobility Aids: Manual W/C, Cane, Walker, Crutches, Comparing “Apples-to-Apples” Product Category Definitions DME Limited Mobility Aids: Manual W/C, Cane, Walker, Crutches, Stationary Commode Chairs, Wound Care and Ostomy Supplies Urological Supplies: Bedpans, Urinals DME includes Limited and- Manual and Electric Beds, Traction Equipment Medical Supplies- Diabetic Supplies, Enteral Products (Non-home visit items) Respiratory- Home medical equipment and supplies covered include respiratory equipment and supplies, oxygen, concentrators, reservoirs, conserving devices, cylinders and oxygen accessories and supplies, home invasive mechanical ventilators, respiratory assist devices, continuous and intermittent positive pressure breathing devices, nebulizers Rehabilitation- Power Mobility devices including complex Rehab and Assistive Technology Orthotics and Prosthetics- Custom fabricated, custom fitted, custom-made orthotics, prosthetic devices, somatic, ocular and facial prosthetics, therapeutic shoes, braces and artificial limbs 44

Accreditation Commission for Healthcare (ACHC) www. achc. org DME- All Equipment Medical Suppliers (Pharmacies) Accreditation Commission for Healthcare (ACHC) www. achc. org DME- All Equipment Medical Suppliers (Pharmacies) Respiratory Rehabilitation Orthotics and Prosthetics 45

American Board of Certification for Orthotics and Prosthetics (ABC of O&P) www. abcop. org American Board of Certification for Orthotics and Prosthetics (ABC of O&P) www. abcop. org Orthotics and Prosthetics DME Limited- Wound Care/Incontinence, Mobility Aids only if in conjunction with O&P Merged with the Board for Certification in Pedorthics (www. cpeds. org) 46

Board of Orthotic/Prosthetist Certification (BOC) www. bocusa. org DME- All Equipment Medical Suppliers (Pharmacies) Board of Orthotic/Prosthetist Certification (BOC) www. bocusa. org DME- All Equipment Medical Suppliers (Pharmacies) Respiratory Orthotics and Prosthetics 47

Commission on Accreditation of Rehabilitation Facilities (CARF) www. carf. org Rehabilitation Orthotics and Prosthetics Commission on Accreditation of Rehabilitation Facilities (CARF) www. carf. org Rehabilitation Orthotics and Prosthetics 48

Community Health Accreditation Program (CHAP) www. chapinc. org DME- All Equipment Medical Suppliers (Pharmacies) Community Health Accreditation Program (CHAP) www. chapinc. org DME- All Equipment Medical Suppliers (Pharmacies) Respiratory Rehabilitation Orthotics and Prosthetics 49

The Compliance Team www. exemplaryprovider. com DME- All Equipment Medical Suppliers (Pharmacies) Respiratory Rehabilitation The Compliance Team www. exemplaryprovider. com DME- All Equipment Medical Suppliers (Pharmacies) Respiratory Rehabilitation Orthotics and Prosthetics 50

Healthcare Quality Association on Accreditation (HQAA) www. hqaa. org DME- All Equipment Medical Suppliers Healthcare Quality Association on Accreditation (HQAA) www. hqaa. org DME- All Equipment Medical Suppliers (Pharmacies) Respiratory Rehabilitation Orthotics and Prosthetics 51

Joint Commission (JCAHO) www. jcaho. org DME- All Equipment Medical Suppliers (Pharmacies) Respiratory Rehabilitation Joint Commission (JCAHO) www. jcaho. org DME- All Equipment Medical Suppliers (Pharmacies) Respiratory Rehabilitation Orthotics and Prosthetics 52

National Association of Boards of Pharmacy (NABP) www. nabp. net DME Limited- Wound Care/Incontinence, National Association of Boards of Pharmacy (NABP) www. nabp. net DME Limited- Wound Care/Incontinence, Mobility Aids Medical Suppliers (Pharmacies) 53

National Board of Accreditation for Orthotic Suppliers (NBAOS) www. nbaos. org Orthotics and Prosthetics National Board of Accreditation for Orthotic Suppliers (NBAOS) www. nbaos. org Orthotics and Prosthetics 54

10 Things You Can Do 10. Download and become VERY comfortable with the final 10 Things You Can Do 10. Download and become VERY comfortable with the final quality standards---read them carefully 9. Monitor the activity of the first 10 MSA’s and updates from the recognized accreditors 8. Review and talk to your payers to make an informed decision as you choose your accreditation provider---especially if you are in any of the first 10 MSA’s 7. Send for your accreditor’s standards and then review and update your P&P (or BUY one!) 6. Identify your team(s)--- review the standards by team and identify what you need to do 55

10 Things You can Do 5 Create a work plan based on what you 10 Things You can Do 5 Create a work plan based on what you need to accomplish (Sample at www. homecaremag. com March 2006 issue) 4. Create/review your PI program NOW– begin to collect patient satisfaction data and implement the required logs ASAP--- Gather at least 3 mos of data before notifying accreditor that you are ready 3. Review all patient education materials to see what you will need to update/change so that they match the final standards 2. Review physical plant, warehouse, vehicles 1. Perform a Mock Survey- make corrections Notify your provider that you’re ready! 56

Stay Tuned! • Work with AAHC on legislative endeavors • More updates from the Stay Tuned! • Work with AAHC on legislative endeavors • More updates from the Recognized Accreditors • Conferences held by the “CBIC” to instruct on Competitive Bidding Applications • Pricing for items for bid in the MSA 57

The Most Effective Way to Survive and Thrive in Your Business is to Be The Most Effective Way to Survive and Thrive in Your Business is to Be Prepared 58

Your Questions ? ? ? 59 Your Questions ? ? ? 59

Thank You! Mary Ellen Conway President Capital Healthcare Group, LLC Bethesda, MD 301 -896 Thank You! Mary Ellen Conway President Capital Healthcare Group, LLC Bethesda, MD 301 -896 -0193 www. capitalhealthcaregroup. com 60