Page 16 - HME Business, November/December 2020

which AO is going to help them through the process,” he says. “It could help them with policy and procedures. It could help them by giving them education.
“After that, I would pick up the phone and see how the application is,” Safley continues. “Is it a friendly application process? How quickly do they answer the phone? And how quickly do they respond to your needs? All of those important, because if you’re just getting started, you want an AO that’s going to help you through the process.”
In the instances where a consultant is involved, there are AOs that train and certify independent consultants. Of course, hiring a consultant costs money; roughly $3,000 to $5,000.
“Can you get through accreditation without a consultant? Yes, you can,” Safley says. “The problem is that for small pharmacies, it’s a struggle because they don’t have time. The pharmacists or the pharm techs are too busy filling the scripts or working behind the counter.”
Besides hiring a certified consultant, Safley advises that providers ensure that the consultant has experience specifically with community pharmacies and pharmacies that carry DME.
And once the policies and procedures are in place, the AO will conduct an unscheduled site survey with the pharmacy. As mentioned, this is typi- cally on-site, but is now virtual during the COVID-19 public health emer- gency (PHE).
“When they’re finished doing their work and through the call series, they complete the form saying, ‘I’m ready; I’ve done all of my implementation work,’” Canally says. “Then, one of our other on-site advisors is the one that verifies and validates that they meet the quality standards.
“Once they complete the on-site — or now during COVID, we’re able to do the virtual — we’re going to send them a scoring report, a certificate of accreditation and a letter of accreditation,” she continues. “At that point, they then put in their 855S, and list The Compliance Team as the accreditor.”
“On a weekly basis, we send a report to CMS that includes all of the companies that are accredited and the Medicare items that they’re accred- ited for and can bill for,” she adds.
COVID-19’S IMPACT
As mentioned, COVID-19 has impacted the accreditation process, start- ing with the site surveys, which are now handled remotely.
Now, it’s important to acknowledge that you might have heard that, around the time of HHS’s initial COVID-19 PHE declaration, CMS imple- mented a waiver from accreditation and reaccreditation activities for DME- POS suppliers. However, effective July 6, CMS resumed all those activities. It even allowed site surveys to be conducted on-site, but most AOs are continuing with virtual site survey services, to comply with local guidelines, their own internal infection control policies, and the preferences and poli- cies of their supplier and pharmacy customers.
So, moving on, how else is COVID-19 impacting the accreditation process?
“There have been no specific changes or guidance to DMEPOS facili- ties in regards to use of PPEs,” Gruskin says. “That being said, per Supplier Standard 1, ‘A supplier must be in compliance with all applicable federal
and state licensure and regulatory requirements.’ This puts the responsibil- ity on the facility as they should be aware of the CDC guidelines for patient care and proper PPE use. I can confidently say that, BOC surveyors have been noting compliance with the CDC guideline in their survey reports.”
There have been certain changes and exceptions post-COVID that were outlined in specific 1135 waivers issued by CMS, Gruskin says. Those waiv- ers are available at cms.gov/files/document/covid-dme.pdf.
“These waivers will expire once the public health emergency (PHE) is lifted,” Gruskin explains. “From an accreditation process perspective, our surveyors, as well as BOC internal facility accreditation staff, are aware of these waivers and are operating in accordance. It is clear that these waivers are temporary and in no way affect the ability for facilities to still meet the quality and supplier standards not addressed the waivers.”
Getting back to virtual site surveys and virtual accreditation processes, the AOs have become practiced hands at accrediting DMEPOS suppliers remotely and there continues to be lots of interest in the process.
“We’ve done more than 300 virtual surveys with all of our programs,” Safley says. “And we’ve had three town hall meetings for people in the DME industry, with more than 1,000 people register for those three different presentations about how virtual surveys work.”
Once the provider provides various policy and procedure documents to the AO, it is then ready for the virtual site survey. Safely says that unlike the typically unscheduled on-site surveys, the AO is allowed to give the sup- plier pharmacy a 48-hour notice that the virtual survey is coming and that they should be ready, since the virtual requires some additional prepara- tion. Once the virtual site survey process starts, it’s very much as one might expect in the era of COVID-19 and Zoom meetings.
“We have a portal where they upload policies, and then we use Face- Time or GoTo Meeting to ‘walk’ around the actual pharmacy or the DME or the clinic, and actually say, ‘Okay, let’s look at that shelf. Let’s look at this and so forth,’” Canally explains. “So it’s very comprehensive. Then at the end, the accreditation goes through scoring and our usual process.”
Assuming the pharmacy passes, it is officially accredited by its AO, which reports that to CMS, according to Canally. That said, the virtual survey pro- cess isn’t a closed loop. CMS still expects an in-person survey to take place.
“We still have to go back once the public health emergency is lifted or certain states have lifted restrictions, then we can go on-site with PPE and so forth and so on, and do the on-site evaluation,” she explains. “We are required by CMS to do an on-site survey within six months to a year after the virtual site survey.”
RENEWAL & ADDING CATEGORIES
Of course, accreditation isn’t static. DMEPOS suppliers must renew their accreditation every three years, and if they want to add product categories, it is likely they will need to work with their AO to be accredited to bill for those items. Accreditation is an ongoing and often expanding activity for
“It’s not all about CMS. And that’s one of the things that people forget. There are other payers.”
—Tim Safley, the Accreditation Commission for Health Care
8 December 2020 | DME Pharmacy
hme-business.com
“What I tell pharmacists is that
you want to have a Medicare part B number to be able to bill and service your Medicare beneficiaries for everything that they need.”
— Sandra Canally, RN, The Compliance Team