The rules have changed. The products and services to be reviewed by an accreditation surveyor have been expanded. Regardless of whether your business is located in one of the competitive bidding cities, any provider that wants to bill Medicare for Durable Medical Equipment, Prosthetics, and Orthotics (DMEPOS) must now be in compliance with the Quality Standards.
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.
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. The harder challenge is getting documentation into the patient file that they actually received this instructional information. It is unclear at this time whether your company may telephone the customer and make a note in the record that confirms they received the instructional information; versus must have a signed and dated document physically returned by the customer. This could be a delivery ticket, or perhaps a pre-printed postage-paid postcard that has the order # written in at the time it is tucked into the box. If the majority of your business is mail-order, you could also use this opportunity to combine questions regarding customer satisfaction on the postcard. Note the last question that is also a bizarre requirement within the Quality Standards Performance Management section.
The burden of creating a tickler system to chase down the postcards or delivery tickets not returned; and matching up the returned forms with the patient will also be new to the provider.
