Page 11 - HME Business, January/February 2021
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“There have been no specific changes
or guidance to DMEPOS facilities in regards to use of PPEs. That being said, per Supplier Standard 1, ‘A supplier must be in compliance with all applicable federal and state licensure and regulatory requirements. ’”
— Matt Gruskin, MBA, BOCO, BOCPD, CDME, the Board of Certification/Accreditation
to be a DMEPOS supplier.
And this year might see a big prolifera-
tion in adding categories. Why? CMS’s pause on competitive bidding continues. At the end of October, CMS announced that after originally taking bids for 16 product categories in the 130 competitive bid areas of Round 2021 of its competitive bidding program, it was only awarding con- tracts for the off-the-shelf back and knees braces categories.
As for the 13 remaining categories (CMS had already removed the non-invasive ventilator category due to the COVID-19 public health emergency), CMS announced it would not issue contracts because it “did not achieve expected savings.” In other words, CMS decided to punt.
That means that given the last competi- tive bidding contracts expired on Dec. 31, 2018, and that the bidding program has since been dormant, DMEPOS providers can continue to provide these 13 catego- ries without contracts.
Even though CMS’s announcement also implied that it had reached a bid floor with DMEPOS reimbursement essen- tially frozen at 2018 rates, the ability for providers to serve new categories without a contract is proving attractive. The key? They need to be accredited for those categories.
There is a huge opportunity for the HMEs to add products that maybe they used to cover,” Canally says. “Maybe it’s years that they haven’t carried oxygen because they didn’t win a bid, and now they’re able to. They still have the understanding of how to utilize oxygen and provide oxygen as a ser- vice; they would need to redo their training and make sure that any new employees are up to speed with manufacturer’s guidelines and so forth and so on.
“But I see it as an opportunity. ... We’ve had a few providers that have added products,” she adds.
When adding a new category, the ac- creditation process is similar. Providers seeking accreditation for a new category must strive to ensure all the proper docu- mentation and procedural steps are in place for the DME and services they offer, and then undergo site surveys — and pos- sibly have to undergo them again if they are found to be in need of improvement in some aspects of their business before they can become accredited.
Also, as mentioned, accreditation has morphed into a strategic asset for DME- POS suppliers. Accreditation is not just a list of tasks that a provider must fulfill in or- der to meet billing requirements on a state or a federal level. Rather, it is a competitive edge that shows customers, physicians and other funding sources that an HME/DME provider delivers solid product category knowledge so that their referral partners and their patients are going to feel that they are working with an expert resource.
As a result, we are now seeing special- ized accreditation and credentialing services emerge from the AOs to help suppliers drive home their expertise with their local market. Examples include the Certified Du- rable Medical Equipment (CDME) specialist certification from BOC, or the Patient-Cen- tered Respiratory Home from The Compli- ance Team. (Moreover, AOs such as The Compliance Team, ACHC, and BOC offer services specifically for pharmacies as well.)
Whether it’s adding a new category or seeking an additional specialized ac- creditation or credentialing, there are a few elements that our experts all noted providers want to start by coordinating with their AO.
“Any products that they add they need to be accredited for by their AO,” Canally explains. “It is connected to any kind of additional billing opportunity. They need to make sure that they contact their accreditor and see what needs to be done.”
THE PHARMACY EXEMPTION
Of course, dedicated HME providers aren’t the only DMEPOS suppliers. DME pharma- cies, the community pharmacies that also provide home and durable medical equip- ment, also can serve DMEPOS clients, but for them, accreditation isn’t as cut and dry.
Why? Those pharmacies can apply for an exemption with Medicare when it comes to DMEPOS accreditation. So, if a DME phar- macy believes the DMEPOS benefit might not play as large a role in their revenues and services in coming years, they might consider that exemption. How should they approach?
“There are really three things you need to have to apply for that exemption,” says Matt Gruskin, MBA, BOCO, BOCPD, CDME, credentialing director for the Board of Cer- tification/Accreditation (bocusa.org). “You need to be enrolled for five years with a PTAN number. You have to have no adverse actions against you. And then you have to have less than 5 percent of your revenue come from DMEPOS. So, for example, if you are dispensing nebulizers to everyone that comes in for albuterol, and you look
at your finances and you’re at 7 percent of your revenue is coming from those nebuliz- ers, you’re not going to qualify for it. So you’re going to need that accreditation still.”
This is important for a community pharmacy offering DME to consider. Even a pharmacy initially starts providing DME not necessarily from a profit perspective, but more in terms of trying to provide a com- munity health service, It could still quickly eclipse that 5 percent, given the reimburse- ment on some of these items.
“It’s something that we focus on when we speak with customers that are pharmacies,” Gruskin says. “You want to provide conti- nuity of care, especially for the community- based pharmacies. So, when the physician refers them to your business, they can ask you questions about their nebulizer. And you know what? Their mother-in-law Might be an insulin-dependent diabetic, and she may get the insulin from you. Well, now you can also dispense the pump as well, right?
“So I do think it’s super relevant for these pharmacies to look at the product catego- ries under the DMEPOS benefit and take
a look at what they’re doing from a Part D perspective and see if any of that comple- ments it,” he adds.
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