Do you ever get complaints?
Does your company ship items to beneficiaries?

If you answer ‘yes’ to either of these questions, you should be aware of new rules within the CMS Quality Standards that affect your company. In August 2006, CMS released the Quality Standards.

COMPLAINTS
Under the heading Consumer Services  #3 (on the third page) it states
“Within five (5) calendar days of receiving a beneficiary’s complaint, the supplier shall notify the beneficiary, using either oral, telephone, email, fax, or letter format, that it has received the complaint and that it is investigating. Within 14 calendar days, the supplier shall provide written notification to the beneficiary of the results of its investigation and response. The supplier shall maintain documentation of all complaints that it receives, copies of the investigations, and responses to beneficiaries.”
When a patient calls and is so upset he/she adamantly wants to talk with a manager, you probably have a documentable complaint on your hands. Telling the patient you will look into the matter happens at the time of that conversation, so complying with the 5 day rule is usually not a problem. The change with which organizations must be vigilant lies with responding IN WRITING and within the 14 day window.
You have always been required to have a complaint log. However, the new version should include a column for date of complaint and date beneficiary notified of resolution. You can download a form from the Palmetto website. Go to www.palmetto.com and follow links to DMERCs, >> national supplier clearinghouse >> supplier enrollment >> standards & compliance >> additional information >> model forms: equipment warranty and beneficiary complaints. After reading NSC’s information about the supplier standard, you can click on the icon of a paperclip at the top of the page to download the documents which include forms and policies.
A second component of the Quality Standards complaint process you should implement is under the heading Performance Management, second bullet point.  It requires,
“at a minimum, that each supplier shall measure…. the timeliness of response to beneficiary questions, problems, and concerns.
That translates to a statement in each Performance Improvement Report summarizing how many complaints your company received and whether the response by your company was within the required timeframe.
INITIAL MAIL ORDER
On page 5 of the CMS Quality Standards, under the heading Training / Instruction to Beneficiary and Caregiver, bullet point 4, it requires:
“Verify that the beneficiary has received training and instructions on the use of items at the time of initial mail order delivery items; and record in the beneficiary’s record that such instruction was provided.”
Many companies provide diabetic or other mail order supplies and historically have been able to prove delivery of these supplies by the UPS Tracking number. Unfortunately, you now need to develop and include some kind of postcard or other document that confirms you sent instructions on the storage or safe use of the supply or device. The headache becomes a migraine when you consider drop shipping directly from the manufacturer. 

The link to the webpage where you can download the CMS Quality standards is: http://www.cms.hhs.gov/CompetitiveAcqforDMEPOS/04_new_quality_standards.asp
Within the October 2006 R3 publication, there is more information on CMS Quality Standards & Accreditation.