Since September 2009, most providers billing to
Medicare have been required to become accredited prior to
applying for their Medicare provider number or to retain their existing
provider number. Many of these providers, however, might not be aware of the
extent of the requirements involved in
compliance, Jim Hewlett CO, BOCO, CII, with Consultants PRN,
Hewlett works with providers to ensure that they meet these standards.
During his time as a consultant, he said he has spoken to many people who give
him the “deer-in-the-headlights” look when he asks if they have a
copy of the
“I am of the opinion that a great majority of Medicare providers
have no idea what the Quality Standards are and what they are supposed to do to
be in compliance,” he said.
The Quality Standards are in addition to the 30 Medicare Standards,
addressing the supplier’s requirements regarding administrative,
financial, human resources, consumer services, performance management, product
safety and information management. These are further explained into product
specific requirements comprising preparation, delivery, set-up, beneficiary
training and follow-up, he said. O&P providers are concerned with Appendix
C of the Quality Standards, which outlines the regulations for orthotics and
“I believe if the supplier chooses to ignore these standards they
are setting themselves up for failure and will have nobody but themselves to
blame,” he said.
He compared non-compliance to driving over the speed limit —
claiming to not know the posted limit is no excuse for speeding when a police
officer pulls you over.
“When an inspector or surveyor [visits] the supplier and evaluates
the supplier’s compliance with the standards, it is no different than
driving 75 mph in a 60 mph zone,” he said.
Reputable businesses should employ some type of performance management
tool to track and measure their progress, he said. Medicare has done just
“If a business owner cannot measure the business’ performance,
he or she will have no idea where the business must go and how to get
there,” he said.
Business owners who fail to set up this performance management tool not
only cannot measure their performance, they also are non-compliant with the
Medicare requirements, which are set up for the benefit of both the supplier
and the patient. Ultimately, “Medicare’s primary objective is to
ensure Medicare beneficiaries receive competent, quality services and
devices,” Hewlett told O&P Business News. The performance
management tools allow suppliers to track and monitor their operations to
deliver that quality and ensure positive outcomes for their patients.
Hewlett offered suggestions for suppliers. First, he said that they
should be sure to share plenty of information about the performance improvement
process with their employees. Furthermore, each employee should assume a role
in the implementation process. They should be required to provide input about
improvements — not only to meet the Quality Standards, but also to improve
The supplier then must carefully evaluate this input and design a
program for implementing these changes, creating an objective measurement tool
for evaluating the effectiveness of the changes, and improving all areas vital
to the company’s success.
A key lesson is that suppliers must not falsify or copy another
“I see this over and over: suppliers simply fabricate data or copy
someone else’s Performance Improvement data, in hopes it will get them
through their survey. Surveyors will see right through this,” Hewlett
said. “[Suppliers] need to be prepared to show that backup data behind
every performance improvement report.”
And it does not matter if the supplier employs 1 or 1,000 people —
every supplier must be compliant with the standards, regardless of size.
Additionally, consultants may be helpful in preparing performance
improvement data; however, “only you can collect your data on an ongoing
basis,” he said. “Remember, a consultant cannot come in and
legitimately produce 3 years of data and reports out of nothing.”
Hewlett said he urges suppliers to be diligent about following a
comprehensive performance improvement system that meets — and even exceeds
— the Quality Standards. Many suppliers not complying with the standards
will find themselves under the scrutiny of the accrediting organizations and/or
The supplier should be able to verify that patient charts are complete
and that every prescription, medical record, physician note and other necessary
document is present and complete, and be aware of these. The best way to ensure
compliance, Hewlett said, is to read the long version of the Medicare Standards
and the CMS Quality Standards, and begin a step-by-step analysis of the
“You cannot afford to be left in the dark,” he said. —
by Stephanie Z. Pavlou
For more information:
- Department of Health and Human Services. Centers for Medicare &
Medicaid Services Durable Medical Equipment, Prosthetics, Orthotics, and
Supplies (DMEPOS) Quality Standards. Available at:
Accessed May 18, 2011.