We know Medicare requires accreditation for bidding HME suppliers to continue providing products to Medicare beneficiaries within the ten competitive bidding cities. The grace period for attaining accreditation is tight: the DMEPOS provider must be accredited by August 31, 2007, literally two months after the bids must be completed and submitted.
WHAT ARE THE OPTIONS?
The organizations named by Medicare as ‘recognized’ for accrediting HME providers are:

1. HealthCare Quality Association on Accreditation (HQAA) (www.hqaa.org)
2. Board of Orthotist / Prosthetist Certification (BOC) (www.bocusa.org)
3. The National Association of Boards of Pharmacy (NABP) (www.nabp.net)
4. The Compliance Team, Inc. (www.exemplaryprovider.com)
5. The Joint Commission (JCAHO) (www.jointcommission.org)
6. Accreditation Commission for Health Care (ACHC) (www.achc.org)
7. Community Health Accreditation Program (CHAP) (www.chapinc.org)

Three other organizations were also named but are only authorized to accredit orthotic providers or rehab facilities: National Board of Accreditation for Orthotic Suppliers, American Board for Certification in Orthotic & Prosthetics and CARF (rehab facilities). These organizations are not authorized to accredit suppliers of durable medical equipment.

The big three accreditation organizations with name recognition are the Joint Commission, CHAP, and ACHC.  It is important to be aware of the full range of options because a pharmacy based HME provider will find the NABP accreditation to be less expensive and complicated than the more well known choices. Another frequently overlooked option available to HME suppliers is the Board of Orthotist / Prosthetist Certification. This organization can accredit a durable medical provider supplier even when it does not provide orthotics or prosthetics. Again, the BOC version of accreditation standards is simpler and far less expensive than the big three. These two options should be seriously considered for the HME provider looking to get accredited only for Medicare purposes. To become a participating provider with payors like Blue Cross/ Blue Shield or other managed care insurers the HME provider must contact the contract rep at the insurer to find out which accreditation organizations meet their criteria—their list is currently much shorter than Medicare’s.

WHAT ABOUT IF YOU ARE NOT IN A COMPETITIVE BIDDING CITY?
First- lucky you. However, don’t think you can stop thinking about accreditation for a few years. Our industry has distributed the Supplier Standards for at least a decade, currently a list of 21 requirements for the HME provider that bills for products provided to Medicare beneficiaries. In August of 2006 CMS released the Quality Standards.  The link to download these standards is: http://www.cms.hhs.gov/CompetitiveAcqforDMEPOS/04_new_quality_standards.asp
CMS states on their website: Suppliers must comply with the quality standards in order to furnish any Durable Medical Equipment (DME), prosthetic device, prosthetic, or orthotic item or service for which Part B makes payment, and also in order to receive or retain a provider or supplier billing number used to submit claims for reimbursement for any such item or service for which payment can be made by Medicare.  No matter where your company is located in the United States, the next time you see a Medicare representative, that person will be looking for activities that support these  extensive standards. Although we are now down to 14 pages from the original draft of several hundred, compliance with these standards should be a priority at your company. 
WHAT’S IN THE CMS QUALITY STANDARDS?
If you are not accredited, these Quality Standards will push you to develop a policy manual that addresses administration, financial management, human resources, how you provide equipment and services, handle complaints, collect information on the performance of your company (performance management), and more.
If your company is already accredited, you already meet or exceed most of the CMS Quality Standards. However, be sure to

1. modify your Customer Satisfaction survey to include a question for the beneficiary asking them about how your company’s business practices impact their access to products and services. This may seem like an odd question, but the thought behind this is linked with Competitive Bidding and the criticism that by having less suppliers and lower reimbursement the beneficiary will loose or have limited access to products they need. They want us to ask the question, but how to pose it to our customers is a challenge. But, before you reprint 1,000 postcards, take a moment to convene your staff and ensure that any specific questions required by CMS and your accreditation organization are on the card.
2. Include ‘billing and coding errors’ in your Performance Improvement data collection and aggregation process. Specifically, CMS wants “frequency of billing and coding errors (e.g. number of Medicare claims denied, errors the supplier finds in its own records after it has been notified of a claims denial)”. CMS wants us to collect data on this topic, present  and trend it in our Performance Improvement reports.
3. Take a look at your policies on Complaint reporting. CMS imposes strict time frames for responding to a beneficiary complaints you probably don’t have. Within five (5) calendar days of receiving a beneficiary’s complaint, you must notify the beneficiary, using either oral, telephone, e-mail, fax, or letter format, that you have received the complaint and that you are investigating. Within 14 calendar days, you must provide written notification to the beneficiary of the results of your investigation and response. You also must maintain documentation of all complaints that you receive, copies of the investigations, and responses to beneficiaries. This is going to take complaint reporting at most HMEs to a new level, with careful time-stamp documentation of date complaint received, and date customer is provided with a follow-up report.
4. Providers of high-end rehab seating and mobility systems must have proof that there is at least one qualified RTS on location; and the rehab techs must have documented proof of 10 hours of in-service / continuing education specific to rehab technology.

Historically, most accreditation organizations turned a blind eye to any HME service provided except rental medical equipment that had been delivered to the patient’s residence. All this changed last year when accreditation organizations became ‘recognized’ by Medicare as part of the mandatory accreditation process for competitive bidding. Medicare now requires that the next time you see an accreditation representative, the surveyor will review any service that is billed on behalf of the patient, regardless of whether the customer walks in the door to pick it up or it is sent as a mail-order supply. Even if your company never bills Medicare, the accreditation organizations are going to apply the CMS Quality Standards consistently to eligible services, regardless of what insurance company or government agency is billed. In particular, prosthetics like mastectomy products, orthotics (either off-the-shelf or custom fabricated); surgical supplies including wound care, diabetic strips, and urologicals will now be included in the survey process.
Legitimate companies will not have any problems with the ‘I. Business Services Requirements’ that address Administration, Financial Management, Human Resource Management, Consumer Services, Performance Management, Product Safety, and Information Management.
Within the ‘II. General Product Specific Standards’ is a possible hitch you may have overlooked if you provide mail order products to the patient. The CMS  requirement is:
Verify that the beneficiary has received training and instructions on the use of items at the time of initial mail order delivery of items; and
• Record in the beneficiary’s record that such instruction was provided.
Historically, providers were allowed to bill CMS with the UPS tracking number as confirmation. This tracking number is not enough to meet the new requirement. Many state Medicaid programs want more documentation than a UPS tracking number too.
For the first (initial) shipped item, your company must ensure the patient received instruction on the item sent. Most diabetic and ostomy supply items have manufacturer-provided instructions; and printed on the box for wound care items are instructions such as ‘Store in a cool dry location…wash your hands with soap & water before handling…’ but you may want to create a one page form that is tucked into the shipping container that is more clearly identified as ‘instructions’ so the customer realizes they actually were provided with this information and confirm receipt of it. The harder challenge is getting documentation into the patient file that they actually received this instructional information. You must have a signed and dated document physically returned by the customer. This will probably be a delivery ticket that has been modified to include a phrase about receipt of instruction in the boiler-plate language signed by the customer. This rule applies even if you have the item drop-shipped direct to the customer from a wholesaler.
When you have an accreditation survey anytime in 2007 forward, the surveyor will not only be reviewing for compliance with their standards, but also the CMS Quality Standards.