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!