Medicare’s Quality Standards require a Performance Improvement program. Although mandatory accreditation is a rolling process linked with competitive bidding areas, compliance with Quality Standards is both nationally and immediately applicable to all medical equipment providers. Surprise visits in the past reviewed for compliance with the 21 Supplier Standards. The next time you have a Medicare site visit, the inspector will be reviewing against the recently released Quality Standards.
A component that has consistently been problematic for HME providers seeking accreditation is Performance Improvement. Now, Performance Improvement is not just for those seeking accreditation- Medicare requires it too. Performance Improvement is a systematic analysis of key operations in your company. This activity has many names, but whether you call it Quality Assurance (QA), Performance Improvement (PI), Improving Organizational Performance (IOP), or Total Quality Management (TQM)……the concept of gathering data about your company to determine how it is performing is a universal requirement by the Medicare Quality Standards. For the purpose of this article, I’ll call it Performance Improvement, but you can call it whatever you want, so long as you do it.
Performance Improvement has been a challenge for many HMEs because most are entrepreneurial and nimble, adjusting process and policies very quickly when a referral source complains or a revenue generating activity fails. Since few in our industry come from a manufacturing background, the concept of Quality Assurance is generally foreign to HME providers. None-the-less, you will find that if you tackle the standards and develop a program that is relevant to your company, it is a worthwhile endeavor.
So how do you make Performance Improvement a real program? First, management must have ‘buy in’ and actively communicate this to the employees. If the corporate attitude is to just go through the motions for the purpose of a survey, it does not take staff long to pick up on this message and dismiss the topic. Second, although it will require an individual to act as primary coordinator for the program, it is wrong for the entire company to think that just one person is responsible for the entire Performance Improvement Process. Everyone should be chartered and enabled (key word here) to identify activities that are counter-productive to an efficient company whose goals are to provide safe, effective medical equipment and to get paid for those services. That means that employees who ‘own’ the process should be on the committee to provide insight to reality and design a way to measure the topic at hand. Take your most vocal employee, perhaps the one who complains a lot, and put them on the committee with the rule that any problem brought to the table must be accompanied by a proposed resolution.
A mistake made by many organizations is to think that PI is only collecting information about customer satisfaction. The Medicare Quality Standards stipulates that at a minimum, each supplier shall measure:
- Timeliness of response to beneficiary questions, problems, and concerns (Read capturing and trending complaints with attention to documenting complaints within 5 calendar days and providing notification to the beneficiary of the results of you investigation and response within 14 days).
- Impact of the supplier’s business practices on the adequacy of beneficiary access to equipment, items, services, and information; (I suggest putting a question on your satisfaction survey: “Please rate the impact of Medicare rules have on your ability to obtain products from <your company name>; or keeping a log of items that are requested that you cannot provide).
- Frequency of billing and coding errors (e.g. number of Medicare claims denied, errors you find in records after you have been notified of a claims denial); and
- Adverse events to beneficiaries due to inadequate or malfunctioning equipment, items, or services (e.g., injuries, accidents, hospitalizations).
- Beneficiary satisfaction with and complaints about product(s) and service(s);
The questions you ask for customer satisfaction, and how you ask them, is up to you (and your accreditation organization). Do you send a postcard, or call the customer? What questions do you ask? Who do you ask (all customers or just certain equipment recipients, only new setups, referral sources….)? It is all up to you. Keep it relevant to what you, the company, want to know about the experience your customers had with your company; and keep it simple.
Once you’ve identified what you specifically are going to collect data on (typically referred to as ‘the plan’) you need to implement it and actually collect the data. Minutes from regular manager meetings can potentially be a source of ideas for Performance Improvement, but the meetings themselves rarely meet the requirements of a Performance Improvement meeting unless specific data is presented and discussed.
A key stipulation is that Performance Improvement must be data driven. For most topics, you must have a numerator and a denominator (18 out of 20 customer satisfaction surveys = 90%). Your company must determine it’s ‘comfort level’ for acceptable results, (typically referred to as a ‘threshold’). Some measures will have a 90% threshold; some, such as if you choose accurate CMN completion for submitted claims, should be 100%. Data should be reviewed by the committee, and if the findings are below acceptable levels, a clear action plan with who is responsible for the activity, when it is going to occur, and what the expected changes will be as a result of the activity should be spelled out in the report. Next quarter, review the results with a second go-round of audits. Did the planned action result in an improvement as anticipated, or does an alternative action need to be proposed because the earlier plan did not result in an improvement?
In the end, if you make this process ‘real’, you will find that it quickly evolves into a dynamic program at your company. As the Nike ad says: ‘Just do it.” Put a date on the calendar, hold the meetings, collect and compare data over time. You’ll find that Performance Improvement is the squeaking wheel that gets the grease. Focus on a problematic issue, let everyone know your company is working on clearly identified target goals, and an amazing evolution towards achievement will occur.
