If you haven’t started preparing for HME accreditation, the clock is ticking. CMS recently announced that all suppliers who want to continue to bill for DMEPOS must be accredited by September 30, 2009. Preparing for your HME survey can take anywhere from four to 18 months. Can you afford to procrastinate and take the risk of not receiving accreditation, therefore losing your supplier number and your ability to serve the Medicare Beneficiary? If your answer to this question is no, then now is the time to start preparing for your survey.
If you have been one of those companies who has been dragging your feet and resisting accreditation, here are some tips for a successful survey.
TIP ONE:
Get your employees involved. Have a kick-off meeting and explain to them the process of becoming accredited, the reason behind it and what their involvement will be. Employees of your organization are the key to a successful survey. Accreditation does not happen and cannot be maintained with only a few designated people involved.
TIP TWO:
Assign the overall implementation to one individual who will coordinate all accreditation activities. To make this process a team effort, assign tasks to other employees and monitor their progress. Examples of tasks could include developing policies and procedures, organizing client and employee records, organizing the warehouse and developing the budget. Hold weekly meetings to assure that implementation of the policies and procedures is occurring. The accreditation coordinator could also serve as your Quality Improvement Coordinator.
TIP THREE:
Get the owners/leaders of the organization involved. The accreditation coordinator should report the progress of accreditation to the owners/leaders on a regular basis. The coordinator must also communicate to the owners/leaders their part in the accreditation survey. Leadership will be responsible for making sure all licensure regulations are being met; establishing goals and communicating these to the employees of the organization; and developing, maintaining and reviewing the budget.
TIP FOUR:
Assemble your client admission documents. All clients are required to receive specific information at the time of receiving services. These documents include: Patient Rights and Responsibilities, Medicare Suppliers Standards; the organization’s complaint process, your HIPPA privacy notice; marketing materials describing your services, hours of business and phone numbers, including after hour contact information; and patient education materials. You must devise a way of documenting the receipt of these documents and have this
documentation available in the client’s chart for the surveyor.
TIP FIVE:
Develop your organizational chart and then write job descriptions for all positions on the chart. Job descriptions should contain key job duties, reporting responsibilities, minimum job qualifications, experience requirements, education and training requirements for the job, and physical and environmental requirements with or without accommodations. After policies and procedures have been developed, training is a key factor. Any or all employees may be interviewed during the onsite survey, so training all employees is important. Look through the standards and any standard that has “Employee Interview” in the evidence section should be a focus area for conducting training sessions.
If you are unclear what documents should be present in a personnel file, you need to refer to the Evidence section following each standard. If “Personnel file” is listed, the surveyor will be looking for some kind of written documentation.
TIP SIX:
Safety and infection control standards are common downfalls for organizations. Take proper infection control measures to protect your staff and clients by using accepted disinfectants, and stress frequent and proper hand washing with all employees. Train all employees on proper infection control procedures, and monitor them for compliance. Set up your warehouse so there is adequate space for dirty equipment. Develop policies on transporting, cleaning and bagging equipment.
All your equipment should be up to date for the manufacturers required maintenance. If you don’t have current service manuals contact the manufacturers for these manuals. You must be able to document that all rental equipment is currently maintained according to the manufacturers’ requirements. If you have not developed a process for tracking serialized equipment, start now. You should be able to track the location either manually or through your computer system.
TIP SEVEN:
At a minimum, your Quality Improvement plan must include: 1) beneficiary satisfaction with and complaints about product(s) and services(s), timeliness of response to beneficiary’s questions, problems and concerns, 2) impact of your business practices on the adequacy of beneficiary access to equipment, items, services and information, 3) frequency of billing and coding errors and adverse events to beneficiaries due to inadequate or malfunctioning equipment, items or services, such as injuries, accidents or hospitalization. Establish acceptable limits or thresholds and implement a plan of correction whenever the limit or threshold has not been achieved. Concentrate on indicators that make sense to your business and can improve your company. These indicators may include after hours calls, timeliness of deliveries, equipment breakdowns, damaged products and employee turnover. Leadership and employee involvement are critical. Communicate QI findings to leadership and your employees and seek input from them in regard to areas that may need improvement.
TIP EIGHT:
There is no specific order that client records need to be organized, but having all records following the same format makes it much easier for the surveyor when they are performing record reviews. When charts are not organized in similar format, it makes it difficult for the surveyor to locate the supporting documents that they are required to observe during the record review process. Multiple files are acceptable, such as Clinical Respiratory or Rehab Technology, but make sure to provide these additional files to the surveyor.
TIP NINE:
Develop Corporate Compliance policies and procedures that address antifraud and abuse controls. All employees must be trained and have knowledge of the organization’s policies for fraud and abuse. Designate one employee to serve as the Corporate Compliance Officer. This person should be responsible for training employees, auditing and investigating any reports of fraud and abuse. Compliance guidelines issued in 1999 from HHS/OIG for DMEPOS are available on their website: http://www.oig.hhs.gov/fraud/complianceguidance. html. You must also document that none of your employees are on the Medicare Exclusion list. This online searchable data base can be located at: http://www.oig.hhs.gov/fraud/exclusions. html.
TIP TEN:
Putting your Preliminary Evidence Report (PER) together is a great way of identifying whether you are in compliance with all the standards and are ready for an unannounced survey. When submitting supporting documents that are required in the PER, refer to the standard. Ask yourself if your policies, forms or other documents contain everything that is mentioned in the standard. If you don’t have to submit a document, can you provide evidence that the standard has been implemented through employee interviews, client records, personnel records or other documents? If the answer to these questions is yes, then you are ready to submit your PER. If the answer is no, take some additional time to fine-tune your policies, do more training with your employees and tweak any other supporting documents. Once your PER is submitted, you are saying that you are ready for your survey.
Your survey is now over. You and your employees have worked hard for many hours to get to this point. So now what? Don’t stop now. Continued compliance is the key to a successful re-survey. Look through the standards and identify what needs to be completed on an annual, semi-annual and quarterly basis. Develop a spreadsheet to assure all of these requirements are completed each year. Your first survey only covers approximately four months of compliance; your next survey covers three years. Continue all the processes. You have worked hard and have seen your organization improve by implementing the standards. Don’t get lax and find yourself back to Tip One in three years. -
Reprinted from the ACHC Surveyor Newsletter with permission. Cindi Hutchinson RCP/RRT is the President of CHX Consulting, Inc., a DMEPOS consulting company located in Indiana specializing in consulting and accreditation preparation. Ms. Hutchinson has over 15 years of experience in the Home Medical Equipment industry and is a surveyor for ACHC. Ms.Hutchinson can be reached at cinhutch@msn.com or (574) 875-7330.