Page 10 - HME Business, January/February 2021

Business Solutions
“Accreditation is not all about CMS. And that’s one of the things people forget. ”
— Tim Safley, the Accreditation Commission for Health Care
plier customers.
When it comes to virtual site surveys and virtual accreditation
processes, the AOs have become practiced hands at accrediting DMEPOS suppliers remotely, and there continues to be much interest in the process.
“We’ve done more than 300 virtual surveys with all of our pro- grams,” 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 supplier a 48-hour notice that the virtual survey is coming and that they should be ready since the virtual requires some additional preparation. 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 DME and actually say, ‘Okay, let’s look at that shelf. Let’s look at this and
so forth,’” Canally explains (TCT was the first AO out of the gate with a virtual process when COVID-19 hit). “So it’s very compre- hensive. Then at the end, the accreditation goes through scoring and our usual process.”
Assuming the provider passes, it is officially accredited by
its AO, which reports that to CMS, according to TCT’s Canally. That said, the virtual survey process 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 evalu- ation,” she explains. “We are required by CMS to do an on-site survey within six months to a year after the virtual site survey.”
POLICIES AND PROCEDURES UNDER COVID-19
As providers review their policies and procedures, one of the things they need to keep in mind is how the pandemic has impacted what they do and how they carry out tasks in relation to their policies and procedures.
“One of the things in reviewing the policies that you want to pay close attention to infection control and emergency prepared- ness, mainly because of the pandemic,” Canally says, adding that this includes how they meet the needs of their employees during this public health emergency, as well as quality improvement.”
This can get a little tricky. While there might not be specific federal requirements, providers need to ensure they are working within all guidelines, including those at the state and local level. So, for instance, while CMS might not have specific requirements related to provisioning a particular product during the PHE, a pro- vider’s state could, and that could still impact their accreditation.
“There have been no specific changes or guidance to DMEPOS facilities in regards to the use of PPEs,” BOC’s Gruskin says. “That being said, per Supplier Standard 1, ‘A supplier must be in compli- ance with all applicable federal and state licensure and regulatory requirements.’ This puts the responsibility 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.”
Also, how a provider actually carries out tasks that are required in policies in procedures related to a product category might change.
“For example, we need to verify and validate that they are giving instruction to the patient,” Canally explains. “So that, how that instruction is being delivered might have changed because of the pandemic.
For instance, the provider’s delivery tech might be out on the doorstep, and the family member comes and picks up the concen- trator, takes it back in, and via FaceTime or even the front window, the tech can actually show them how to adjust the settings.
“But the end of the day, the requirements are still there with ensuring that the patient understands how to operate the equip- ment, how to use it correctly,” she says. “The importance of appropriate and comprehensive instruction is really key. We don’t want Joe the delivery guy to have to go back, especially during a pandemic.”
And, of course, controlling any and all bloodborne pathogens is particularly important right now. COVID-19 has underscored the importance of any and all infection control.
“If providers offer services where their employees are at risk for exposure, they do annual training on that issue,” Canally advises. “This includes offering the hepatitis B vaccination, if those folks are at risk, like delivery people, or people in the warehouse that are cleaning dirty equipment on a regular basis. You have post- ings that need to be taken care of and training on that. Hazard- ous material. There are all sorts of things that come under this annual training umbrella.”
ANOTHER CHANGE: CMS’S ROUND 2021 PUNT
Of course, accreditation isn’t static. When DMEPOS suppliers renew their accreditation every three years, they might want to add product categories, and they will need to work with their AO to be accredited to bill for those items. Accreditation is an ongo- ing and often expanding activity for any DME pharmacy looking
“One of the things in reviewing policies that you want to pay close attention to infection control and emergency preparedness, because of the pandemic.”
— Sandra Canally, RN, The Compliance Team
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