The announcement may have taken some time in coming, but it was an important step toward creating a national standard for the orthotic and prosthetic profession. Recently, the Centers for Medicare and Medicaid Services (CMS) named which national accreditation organizations can accredit suppliers of durable medical equipment, prosthetics, orthotics and supplies (DMEPOS) as meeting the new quality standards under Medicare Part B. In doing so, the 11 organizations now have deeming authority to accredit DMEPOS suppliers seeking to participate in the Medicare program (see sidebar on page 49 for the complete list).
Most of the accreditation organizations are authorized to accredit all major supplier types, and most are able to accredit both national and local suppliers, as well as mail order companies. Information about the types of suppliers each accrediting organization is approved to accredit and how to contact a deemed accrediting organization is posted on the CMS Web site.
“The announcement represents the next step in CMS’ effort to ensure that Medicare beneficiaries have access to high quality items of durable medical equipment, prosthetics, and orthotics at the right price, and that they receive high quality service from the suppliers of these items,” said Leslie V. Norwalk, Esq., CMS acting administrator, in a press release. “This is part of a larger vision set out in CMS’ Strategic Action Plan to foster a health care system that ensures quality care for all persons with Medicare.”
Billing Medicare
DMEPOS suppliers have to meet new quality standards in order to be able to bill the Medicare Part B program for durable medical equipment, prosthetics, orthotics or prosthetic devices, such as walkers, wheelchairs, and hospital beds, furnished to Medicare beneficiaries. The requirement that CMS-approved accreditation organizations apply quality standards to DMEPOS suppliers was enacted as part of the Medicare Modernization Act of 2003, therefore requiring all suppliers to submit to mandatory facility accreditation is a central part of these new standards. CMS also is relying on these 11 non-governmental accrediting organizations to evaluate all locations of patient care against established Medicare Quality Standards. The Medicare Modernization Act also requires CMS to implement competitive bidding for certain items of DMEPOS.
CMS hopes to minimize the burden on suppliers by having the accreditation organizations consider during the survey process the previous accreditation, Medicare certification and licensure that would indicate that the quality standards are being met. In addition, CMS will instruct accrediting organizations to focus first on suppliers in the initial group of metropolitan statistical areas chosen for the competitive bidding program.
The new national standard
As accreditation becomes the national standard for all O&P practices, facilities that provide services to Medicare beneficiaries are required to meet these accreditation standards. While these standards vary slightly from one accrediting organization to another, all are modeled on CMS’ Quality Standards and require similar survey mechanisms. This means that those companies who cannot meet accreditation requirements will be forced to either modernize their practice or face losing their National Provider Identifier.
Tom Derrick, public relations, marketing and professional discipline manager for the American Board for Certification in Orthotics and Prosthetics (ABC), said that over time, ABC officials are optimistic that the accreditation standards will help to level the playing field by forcing all O&P providers to meet similar objective standards for the first time.
“We anticipate insurance companies following the CMS lead and requiring accreditation for inclusion in their provider networks,” he said.
Jim Newberry, BOCPO, LPO, interim executive director of the Board for Orthotist/Prosthetist Certification (BOC), said that although the accreditation standards have both good and bad points, having everyone meet the same standards is good for the O&P profession overall.
“The accreditation standards are giving us some ground rules and maybe with the facility accreditation, we can do a better job of governing our own profession,” he said.
CMS also recognized the Board for Certification in Pedorthics (BCP) as an accrediting organization for suppliers of DMEPOS. In a vote late last year, certified pedorthists approved the integration of the BCP into ABC, which occurred on Jan. 1.
“With both BCP and ABC being recognized by CMS, this federal acknowledgement greatly enhances BCP’s ability to join with the ABC as an equal partner in providing quality medical foot care services to the public,” David Cardillo, BCP president, said in a press release. “It also provides an extra dimension of quality assurance for our patients — a confirmation that our profession adheres to the highest standards of service.”
Approved prerequisite
ABC and BOC officials said that with the announcement, CMS validated their accreditation program and established accreditation as an approved prerequisite for suppliers of prosthetics, orthotics and pedorthics.
“For O&P practitioners, the announcement that ABC has achieved CMS deemed status means a facility’s status as an ABC-accredited facility will satisfy Medicare’s new mandatory accreditation requirement. For those practitioners, practice managers and business owners whose facilities have not yet achieved ABC accreditation, they should feel confident knowing that when they achieve ABC accreditation, they will be taking a significant step forward in maintaining the ability to serve the Medicare population,” Derrick told O&P Bnusiess News.
Jeffrey Yakovich, CO, president of the ABC, said in a press release, that CMS’ decision has mandated accreditation for all providers, which is going to lead to profound changes in the O&P profession. All facilities have to meet objective performance standards, and those O&P patient care sites that cannot meet the accreditation standards could lose their ability to provide services to Medicare beneficiaries.
Derrick said CMS approved ABC to accredit the entire spectrum of orthotic, prosthetic and pedorthic patient care locations. Newberry said CMS approved the BOC to accredit all DME and orthotics and prosthetics, including mastectomy products.
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Changes ahead
Both Derrick and Newberry said that their organizations’ accreditation program will change this year as officials work to integrate all the new CMS Quality Standards.
“We are making some changes, but the board has instructed the Facility Accreditation Committee and staff to continue our consultative, affordable approach,” Derrick said.
One of the first changes ABC and BOC will make is a modification of the survey process. To comply with CMS regulations, all accreditation surveys must be unannounced, in contrast to scheduled surveys or video site surveys. The intent of this CMS mandated change is to ensure that facilities maintain high standards on an everyday basis. Current ABC and BOC accredited facilities will be receiving further information on this process change.
A second change will be the addition of a new Supplier Compliance section to the existing accreditation standards. This is a requirement of the CMS Quality Standards and helps ensure that those responsible for billing CMS are qualified to do so.
ABC and BOC are also expanding the accreditation options offered. ABC’s central program, Comprehensive Orthotic & Prosthetic Accreditation, will continue to be the organization’s flagship accreditation option. In order to serve the entire spectrum of O&P suppliers, Derrick said ABC now offers the following additional accreditation programs:
- Comprehensive Orthotics and Prosthetics Accreditation is designed for organizations providing custom fabricated and fit orthotic and/or prosthetic patient care services. Accreditation standards require these services to be provided by a certified or licensed orthotic or prosthetic practitioner. This accreditation encompasses the scope of services accredited under the Prefabricated Orthotics, Off-the-Shelf Orthotics, Comprehensive Pedorthic and Non-Custom Therapeutic Shoe Accreditation programs.
- Prefabricated Orthotics Accreditation
- Comprehensive Pedorthics Accreditation
- Non-Custom Therapeutic Footwear Accreditation
- Post-Mastectomy Accreditation.
- Off-the-Shelf Orthotics
BOC officials said that their accreditation options include the same areas, in addition to accrediting DMEs, a recent supplement to the BOC program.
In addition to the new accreditation options, facilities that qualify for Comprehensive O&P Accreditation will have the option of adding on accreditation for Ancillary Assistive Devices. This add-on accreditation covers facilities that provide canes, walkers and crutches in addition to O&P services.
The ABC accreditation program was established in 1948. Currently, more than 1,450 facilities abide by ABC accreditation standards and ABC is preparing for an influx in applications and accredited facilities through increased surveyor training, the establishment of streamlined survey processes and the hiring of new office staff.
“We are prepared and looking forward to hundreds and eventually thousands of new facilities joining the current ABC accredited facilities,” Derrick said.
Cardillo said that the BCP has made a few changes in its existing structure to meet new federal rules, and the result is a strong and robust accreditation program. For example, he said, new federal rules require that accredited facilities be subject to an onsite survey, so the BCP rules now mirror that requirement.
Newberry said the BOC also plans to revise their application and streamline their application process. He anticipated a minimum of 800 facilities joining the BOC. Additional staff will be needed for the anticipated increase in facility accreditation applications, he said. BOC officials also will offer education campaigns and conferences so suppliers can learn more about the competitive bidding process and facility accreditation program. Established in 1984, the BOC accreditation program has more than 250 accredited facilities as of last year.
Investing in your business
Derrick said that ABC accreditation should not be viewed as an excess regulation from the federal government, rather than as an investment in an O&P business. He said ABC’s consultative survey process may help streamline a business, from helping practice managers to establish better organizational policies to forcing a facility to implement current facility safety guidelines.
“In fact, last year an ABC surveyor discovered $10,000 worth of billing errors in favor of an established O&P facility,” he said.
Newberry said that even though there are a lot of unknown factors, at least there is a national standard for everyone to meet. He hopes some larger standards will be added for O&P services, but for now, the profession has to work for better improvements from here.
“There are a lot of new players,” he said. “Medicare may deem this competition but the other players need to have some idea, especially if they have only been dealing with hospitals or big institutions and not in the world of DME and O&P.”— by Kristine Houck
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For more information:
- The CMS Quality Standards can be viewed on the Medicare Learning Network section of www.oandpcare.org/MLN.
- ABC’s fees for accreditation will be kept to a minimum per instructions from the board of directors. The new ABC accreditation guide and application are available online at www.abcop.org or by calling (703) 836-7114 ext. 230. Accreditation questions can be e-mailed to accreditation@abcop.org.
- The BOC facility accreditation application and information are available online at www.bocusa.org or by calling (877) 776-2200.
