CMS Accreditation Update - The Latest from the MSAs: What Do You Need to Do and When Do You Need to Be Ready? Tuesday, October 2, 2007 MedTrade. Mary Ellen Conway President

2 Overview What is the Accreditation Requirement? First 10 MSA’s, Next 70 When do YOU Need to be Ready? Current Important Legislative Activity “Inconspicuous Items” Report from the First 10 CBA’s

3 Overview Continued How Do You Get Started? Tips on Choosing Your Accreditor –Issues with fees/costs The Current Ten Recognized Accreditation Providers Models/Formats Video Examples Main Reasons Organizations Fail How Long Does It Take? Ten Things You Can Do Now to be Ready

4 Common Acronyms CBA Competitive Bid Area CBIC Competitive Bidding Implementation Contractor CMS Center for Medicare Medicaid Services DME Durable Medical Equipment DMEPOSDurable Medical Equipment, Prosthetics, Orthotics and Supplies HMEHome Medical Equipment MMA ’03Medicare Modernization Act of ’03 MSAMetropolitan Statistical Area

5 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 this will be enforced initially through the Competitive Bidding Requirement There are between 117,000 and 150,000 Medicare Part B supplier numbers This applies to DME’s as well as pharmacies billing for identified items

6 The “Dominos” CMS is enforcing the law that requires competitive bidding in 2007 (Slated to begin July 2008) Only accredited organizations can be awarded a bid Accreditation must be by recognized accreditors Provider must comply with Final Quality Standards (Released )

7 Why is this happening? High profile fraud and abuse cases New price list alone will not solve

8 Competitive Bidding Timeline Bidding opened May 15, 2007 Bidding closed September 26, 2007 Competitive bidding contracts will be awarded for 3 years (with the exception of mail order diabetic supplies), starting July 1, 2008 in the identified 10 CBA’s and in a additional 70 (for a total of 80) to begin July 1, 2009 See website

9 The First 10 CBA’s 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

10 Next 80 Largest MSA’s Los AngelesNew YorkChicagoSan Diego Washington, DCSt Louis, MO/ILRichmond, VALouisville PhoenixSeattleHoustonAtlanta Nassua/SuffolkOakland, CADenverNewark, NJ Portland, ORFt Worth, TXLas VegasSan Jose, CA BostonIndianapolisSan AntonioVirginia Beach Columbus, OHMilwaukeeBergen, NJNew Orleans Salk Lake CityGreensboro, NCAustinNashville Providence. RIRaleigh/DurhamHartfordBuffalo Middlesex/SomersetMemphisW Palm/BocaMonmouth JacksonvilleRochester, NYGrand RapidsFresno Philadelphia, PASan Francisco, CATampaDetroit

11 Next 80 Largest MSA’s Con’t Oklahoma CityGreenville, SCDayton, OHHonolulu AlbanyTucsonTulsaVentura, CA SyracuseOmahaAlbuquerqueAkron KnoxvilleEl PasoBakersfieldGary, IN Allentown, PAHarrisburgScrantonToledo, OH Jersey CityBaton RougeYoungstown, OHSpringfield, MA Little RockAnn ArborStockton, CAWichita CharlestonNew Haven, CTMobile, ALColumbia, SC McAllen/Edinburg, TXSarasota/Bradenton

12 The CBA (Competitive Bid Area) Can be multiple MSA’s –Applies to defined Zip Codes where the beneficiary resides, not where the provider is located –Check CBIC website for service area zip codes- can be an enormous service area

13 When Do You Need to Be Ready? If you provide any of the identified products or services to Medicare beneficiaries in any of the defined areas and wish to continue, you will be required to bid. In order to bid, you will need to be accredited If you do not bid, or do not win the bid, you are excluded for three years- you CAN NOT bill from an office in another area All others may be required to be accredited (whether or not there is Competitive Bidding in your service area) as early as April 1, 2009 “Everyone else after that”

14 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 finite date

15 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 mattresses and overlays) in Miami and San Juan only

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

17 Legislative Activity

18 What’s the update from the First 10 CBA’s?

19 Deadlines were VERY tight Many suppliers had their applications and funds returned at the end of June/beginning of July (before the extension was announced) from accreditors For many who were surveyed in time, they had extensive amounts of follow-up that needed to be done due to incomplete work. This often included re-visits All has to be complete by October 31st

20 Multiple Bidding Issues Geographic area in each was VERY extensive Capacity issues- wait to be seen who is awarded bids

21 The Next 70? Complaints in Florida about 20 minute accreditation surveys Results of validation surveys? –PAOC Meeting scheduled for October 11, Baltimore, MD CMS announced that they are ready for the next 70 CBA’s- could be before the first round contracts begin –Herb Kuhn, AAHC Legislative Conference, June 6

How Do I Get Started???

23 Must Have 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

24 Performance Improvement Examples are Everywhere… Where do you see them?

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27 Tips to Use in Choosing Your Accreditor CMS is not your only payer! –Payer or state licensure requirements to be accredited ex: Anthem BC, State of Florida, Oklahoma Medicaid What is the accreditor’s schedule and what are the requirements for in-between? –ex: Triennial and or annual updates Fees paid vs. administrative costs Other services (infusion, home health) Process (electronic vs. paper) Interview/discussions with accrediting organization— your perceptions Your peer’s experience

The Current Ten Recognized Accreditors Not every organization is an option for you

29 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

30 Accreditation Commission for Healthcare (ACHC) DME- All Equipment Medical Suppliers (Pharmacies) Respiratory Rehabilitation Orthotics and Prosthetics

31 American Board of Certification for Orthotics and Prosthetics (ABC of O&P) 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 (

32 Board of Orthotic/Prosthetist Certification (BOC) DME- All Equipment Medical Suppliers (Pharmacies) Respiratory Orthotics and Prosthetics

33 Commission on Accreditation of Rehabilitation Facilities (CARF) Rehabilitation Orthotics and Prosthetics

34 Community Health Accreditation Program (CHAP) DME- All Equipment Medical Suppliers (Pharmacies) Respiratory Rehabilitation Orthotics and Prosthetics

35 The Compliance Team DME- All Equipment Medical Suppliers (Pharmacies) Respiratory Rehabilitation Orthotics and Prosthetics

36 Healthcare Quality Association on Accreditation (HQAA) DME- All Equipment Medical Suppliers (Pharmacies) Respiratory Rehabilitation Orthotics and Prosthetics

37 Joint Commission (JCAHO) DME- All Equipment Medical Suppliers (Pharmacies) Respiratory Rehabilitation Orthotics and Prosthetics

38 National Association of Boards of Pharmacy (NABP) DME Limited- Wound Care/Incontinence, Mobility Aids Medical Suppliers (Pharmacies)

39 National Board of Accreditation for Orthotic Suppliers (NBAOS) Orthotics and Prosthetics

40 Models/Formats Models/Format of Programs Additionally –Paper Based vs Electronic

41 Video Examples Anxiety about the Surveyor Home Visit

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43 Home Visits GO OUT AND SEE WHAT’S HAPPENING!!! Surveyors will interview patients, asking how they were oriented, how to reach the office, how the services has been, any problems…

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45 Main Reasons Organization Fail Lack of Preparedness Few Staff Aware of Process/Requirements Lack of Focus and Follow-through Main items: –Physician Orders –Infection Control –Incomplete HR Files

46 How Long Does It Take? Generally at least 4 – 6 months from start to completion Do you have everything you need? –Policies and Procedures, Educational Materials, etc. –How long will it take for you to get these in place? Once you gather your information, how long will it take for you to coordinate and submit your materials? –Average is 2 – 3 months When you notify your accreditation company that you are ready, how long until your survey? –Schedules are usually 45 – 60 days in advance-Surveys must be un-announced within a window of time that you are ready

47 10 Things You Can Do 1.Download and become VERY comfortable with the final quality standards---read them carefully 2.Review and talk to your payers to make an informed decision as you choose your accreditation provider right away 3. Send for your accreditor’s standards ASAP 4. Review and update your P&P (or BUY one!) Identify your team(s)--- review the standards by team and identify what you need to do

48 10 Things You can Do 6.Educate the staff NOW- practice discussions 7.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 8.Review all patient education materials to see what you will need to update/change so that they match the final standards 9.Review physical plant, warehouse, vehicles 10.Perform a Mock Survey- make corrections Notify your provider that you’re ready!

49 Stay Tuned! Watch for updates in the media on a weekly basis Release of the next 70 CBA’s (can be multiple MSA’s) Conferences held by the CBIC to instruct beneficiaries Pricing for items for bid in the first CBA’s

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

51 Your Questions ???

52 Thank You! Mary Ellen Conway President Capital Healthcare Group, LLC Bethesda, MD