Tuesday, September 09, 2008
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Following the CMS conference call last week, I decided to email specific questions to the CMS staff to clarify a few valid points pertaining to FA Exemption. I did receive an email response; however, I also received a telephone call later today to discuss some of my questions and concerns in greater detail. I applaud the CMS staff for taking the initiative to call me to discuss and clarify important facts. After the telephone conversation with a member of the CMS staff, here are some of the facts that you should be aware of:
1. Orthotic Fitters are Not Exempt from Facility Accreditation
2. Mastectomy Fitters (non custom) are Not Exempt from Facility Accreditation
3. Durable Medical Equipment Providers are Not Exempt from Facility Accreditation
4. O&P Providers and/or Pedorthists May Not be Exempt from Facility Accreditation IF THEY ALSO PROVIDE ANY TYPE OF DME, MASTECTOMY FITTER PRODUCTS AND ORTHOTIC FITTER PRODUCTS.
5. DMEPOS providers are NOT EXCLUDED from Facility Accreditation altogether, at this time, JUST UNTIL SEPTEMBER 30, 2009...just as I suspected was the case.
6. It is my opinion that DMEPOS providers should proceed with Facility Accreditation to avoid potential risks of Facility Accreditation mandates after the rule making changes. It will become more clear that the Newly Revised Quality Standards for DMEPOS providers are going to be more complexed, and some facilities may have to be re-surveyed after the Newly Revised Quality Standards are finalized next year (2009.)
7. Again, the Revised Quality Standards will come out in early 2009, and will be available for public comment for approximately 45 days. After the 45 days are exhausted, CMS will take all comments into consideration and make a final ruling relating to the Revised Quality Standards, and these new standards will go into force immediately thereafter, in 2009.
8. Most major insurance companies and/or managed care organizations are mandating Facility Accreditation for all DMEPOS providers, in order to participate in, and have billing privledges and be paid, in or out of network. In fact, I received a call today from a non network provider where BCBS told the provider that they would not pay his claim without Facility Accreditation. This actually happened today!
With all this being said and noted, it may not be in your best interest to have a facility that is not accredited by one of the approved accrediting organizations, as this could come back to haunt you later.
Be Proactive, Take Charge of your Practice and one step ahead of the challenge!
I attended a conference call last week, conducted by the CMS staff, relating to Facility Accreditation
"Changes and Revisions" of the DMEPOS Quality Standards. Prior to attending the conference call, I received an email alert on August 21, 2008 relating to the open door forum conference call, which included a new subparagraph that was added and would be discussed during the call. Here is the new subparagraph that was added to MIPPA section 154(b)subparagraph(F):
Background:
MIPPA section 154(b) added a new subparagraph (F). This subparagraph states that eligible professionals and other persons are exempt from meeting the September 30, 2009 accreditation deadline until CMS determines that the quality standards are specifically designed to apply to such professionals and other persons. MIPPA also states that CMS may exempt such professionals and persons from the quality standards based on their licensing, accreditation or other mandatory quality requirements that may apply.
Needless to say, after the conference call had ended, there were A LOT of happy providers, and A LOT of angry providers!
Why? (There’s that question again) The reason some were happy is that the NON DME providers are now “Exempt” from the previous mandated Facility Accreditation, with the appropriate Licensing and/or Certification indicating companies have qualified professionals on staff to provide these services.
The reason DMEPOS providers are angry is that so many providers went to extreme measures to get their practice in tip top shape to pass the Accreditation process, and receive Accreditation Certification, in order to maintain their Medicare Supplier Billing Number, to bill Medicare. Many have gone through the lengthy process and paid THOUSANDS of dollars to prepare for inspection. Others have paid the hefty accreditation application fees and now wonder if they should proceed and follow through, or count it a loss and say “forget it, cancel my application.”
With that being said, many may ask the question…Was it worth it to get Facility Accreditation, or proceeding with the process, for your business? You bet it was and is! Furthermore, I would personally recommend that you not only get it, but you keep it current when renewal comes around again.
The fact is…during the conference call, CMS staff indicated that CMS is changing administration within the next six (6) months, and undergoing a New Rule Making process right now, to identify and change the DMEPOS quality standards, to determine and specify things like…”what qualifies a DMEPOS supplier from Facility Accreditation Exemption”. The revised quality standards are supposed to be completed in early 2009, and then placed for public comments for a period of at least 45 days, before the final draft is complete. So, by September 30, 2009 the revised Quality Standards and new standards ruling for DMEPOS providers should be complete and set in place.
CMS staff also indicated that the revised quality standards may be broken down into categories of professionals, dispensing products and who is qualified to fit and deliver these products.
I could go on and on about this, but I will stop for now. I do believe that smart business people will keep their facility accreditation current, and that all other DMEPOS providers keep going through the process to get it.
The reason I say this is because CMS can come back at any time and make another change, demanding it once again, then you may be one scurrying through the process all over again...ultimately, leading to major frustration! Furthermore, Accreditation and Quality Assurance Programs ADD value to your, or any practice.
In my opinion, Facility Accreditation is a no brainer…a smart move to protect you and your business!
How many times have you heard, or even said, “Because I Said So” when asking the question, Why? I know as a child, my parents would simply reply in this same manner when I asked Why. In fact I have to admit that I have even used the response with my children as well, a time or two…although seldom.
The fact is, asking the right questions can sometimes lead to getting the right answers to satisfy the why factor. In addition, when answering the question at once, you leave less room for the same question to come up again and again at a later date, which may ultimately lead to further frustration from both parties.
For example, I recently verified insurance for a couple of patients to determine eligibility and coverage of benefits for a Knee Orthosis. When speaking with a customer service representative from the insurance company, sometimes I believe they are programmed to give you very basic information about the patient’s eligibility and coverage, and try to leave it at that. This is where your expertise comes into play…I let the CSR give me the low down on the basic coverage and benefits, and then I was in hot pursuit to inquire about more specifics about the coverage and benefits.
I proceeded to ask if there were any limitations, exclusions and/or provisions on their plan pertaining to Orthotics. That is when the CSR came back with the answer…Prefabricated Knee Orthosis are not a covered benefit under the patient’s benefit plan. Hmmmmmmm, I thought. Had I not asked, they would not have told. Had the practitioner fit a prefabricated KO, then the claim would have been denied. If the claim had been denied, then you would probably have a very angry patient who finds out later that they may have to pay for the brace out of their own pocket, or they would have a legitimate argument to avoid paying the bill because you or your staff may have told the patient that the Knee Brace was covered, when in reality it wasn’t for a prefabricated KO.
In a nutshell, it is alright to ask “Why” when you feel that you need further explanation. This is especially important when you’re dealing with insurance companies to verify insurance. The key is to “ask the right questions” so that you can determine if you will be paid for your services. Are you asking the right questions pertaining to the type of service(s) that you plan to provide to your patients? If not, you could be in a heap of trouble!