Reimbursement: Accreditation
A provision in the Medicare Prescription Drug Improvement and Modernization Act of 2003 calls for mandatory accreditation for HME providers who wish to supply products to Medicare patients. While no deadline has been set by CMS at this point, it's a fairly safe bet that accreditation will be required by the time competitive bidding begins to be implemented in 2006. Mandatory accreditation is not necessarily bad news for the industry. In fact it may well level the playing field among industry participants in the Medicare program, ensuring that minimum quality standards are observed by all. However, navigating the accreditation process may represent a challenge to some suppliers that up to this point have not pursued formal recognition of the quality care that they provide to patients.
In our last installment we discussed factors to consider when choosing an accreditation organization to survey your company, and the various patient and equipment documentation requirements that must be met in order to successfully complete an accreditation survey. This month I will focus on other areas that commonly trip up HME providers seeking accreditation such as employee training and competency programs, infection control processes, and performance improvement activities.
Employee Training and Competency Testing
The HME provider's employee orientation, training and competency testing program usually receives quite a bit of focus during any accreditation survey, and it's easy to see why. It takes well trained, knowledgeable employees to provide quality services to patients who are oftentimes unfamiliar with the equipment that has been ordered by their physician as part of their treatment plan. Since there are no formal college or vocational programs geared toward learning the art of providing home medical equipment to patients, it is most often the HME provider who must train and ensure the competency of its employees.
The accreditation organization will assess a company's training and competency testing program in a variety of ways by reviewing employee personnel files to determine what training as been provided; by interviewing employees to assess their knowledge; and by observing employees as they go about completing their assigned duties.
Any successful training program starts with a thorough orientation program for newly hired employees. Even if an employee has many years of experience in the field of HME previous to coming on board with your company a rigorous orientation program is necessary to make sure that they understand the policies, procedures, and processes followed by your organization. A formal orientation process can and should take many weeks to complete and can be accomplished as the employee gradually takes on more and more responsibility in their assigned role until they are able to work independently.
It is very likely that even non-accredited companies follow an orientation process with newly hired employees. The key here is to document those activities and to secure that documentation in the employee's personnel file. To that end, it is wise to create an orientation outline that includes a list of all the areas your company will cover as the employee is trained. The outline should typically include check-offs for the company's personnel policies, patient care policies, infection control procedures, billing and reimbursement policies, performance improvement activities, patient confidentiality and privacy policies, and emergency preparedness planning and that's just for starters. Take great care when developing an orientation outline to follow when training employees who are new to your organization because it will set the standard for your company's entire training program.
Once you have covered the basics with your employees you will also need to assess their competency as it relates to completing assigned job duties. This is most important in the areas of patient care activities and proper, safe use of equipment. An effective competency testing program may include objective testing such as a multiple choice test, or use more subjective methods of assessment such as an observation of an employee instructing the patient on the use of a particular piece of equipment. The best competency testing programs typically incorporate both objective and subjective assessments of an employee's competency.
As you design your organization's competency testing program make sure to define which competencies should be completed at orientation and which are important enough for your company to require the employee to complete on a periodic and ongoing basis. Choosing competencies based on high volume activities or high risk care areas are usually your best bet. Make sure to document your organization's competency testing activities and include the information in the employee files of the individual staff members who have completed the testing. Remember that training certificates earned by your employees through outside programs such as those provided by vendors or industry association organizations also count toward your competency testing program and should be included in the employee's personnel file.
Lastly, be aware that accrediting organizations require that certain employees receive training in specific areas on an annual basis, such as hazardous material training, blood borne pathogen and tuberculosis in-services, and employee and patient safety training. Again, be sure to document that this training has been completed.
Infection Control
Your company's infection control processes and plan will also be a focus of any accreditation survey. Typically the accrediting body will assess your company's infection control plan through observation and interviews of staff members, observation of home visits with patients, and a review of the company's policies and procedures. The policies and procedures your company designs in this area will also serve to educate and guide your employees on proper infection control processes so take great care when developing these. In general, your policies should cover at least these main areas:
Surveillance
the collection of data on a specific patient population or specific service provided in order to identify potential problem areas.
Identification
how your company identifies trends among the data collected to help guide your infection control plan and staff education activities.
Prevention
what measures your company takes to prevent infection among patients and employees, again, including staff education activities.
Exposure Control
what measures your company takes to control exposures and how it reacts to them once an exposure is identified.
Reporting
the process your company follows for reporting infections as mandated by state laws.
While nearly every policy and procedure your company designs around the subject of infection control will likely be reviewed during an accreditation survey, even the best infection control plan will not pass muster unless your employees follow it scrupulously. Therefore it is critical that your employees are well trained and have a full understanding of the infection control plan that your company has put into place.
Performance Improvement
An effective performance improvement process is vital not just to the successful completion of the accreditation process, but also to the success and profitability of your business as a whole. If your company is not currently accredited it may not have a formal performance improvement process in place, nonetheless, chances are that every staff member from equipment technician to the company owner or manager engages in performance improvement activities on a routine basis even if they don't quite realize they are doing just that. Every time your organizations identifies a problem, weighs the options for solving the problem, implements the chosen solution, then assesses whether that solution has actually solved the problem it is engaging in performance improvement. Companies seeking accreditation must simply formalize this process and document these activities.
It is not possible for an organization to work on each and every area it wishes to improve simultaneously so it is important to choose performance improvement activities that matter most and are relevant to your business. You can begin the process by listing all the areas that are judged to have a potential for improvement then choose activities based on a priority ranking system. It is reasonable to assume that most companies can engage in performance improvement related to two to four specific items at any one time.
Once you begin to engage in formal performance improvement program it is important that you use objective data to guide your activities. You'll need to collect, aggregate and assess data related to the specific performance improvement indicator that is being addressed on a regular basis, in accordance with your organization's policies and procedures?typically quarterly?until the data indicates that the performance goal has been reached.
For instance, if service calls have increased because patients are befuddled by how to use their equipment shortly after set-up perhaps the solution is to beef up the patient education program and ensure that patient care staff members are covering all the necessary educational components when communicating with patients. In that case your company may choose to design simple written patient education handouts that reiterate the information provided verbally to patients when they first receive their equipment, and provide a checklist to employees that documents what points need to be covered during the set-up of specific equipment.
As you implement the new patient education program continue to collect data to assess whether these types of patient calls have decreased. If so, you'll know that the solution you implemented was successful. If not, you'll need to go back and determine why the number of calls has not decreased, then redesign the process until the problem is deemed to be solved.
Whatever you do, remember to respond to data you collect, either by redesigning processes until the problem is solved, or by discontinuing the collection of data on a specific indicator once the problem has been solved and moving on to another performance improvement activity. Keep in mind that every employee has a role in performance improvement, whether it is helping to identify potential areas of improvement, helping to design process improvements or implementing solutions. And of course, involvement by the leadership of the organization is mandatory. Their role is to help prioritize performance improvement activities, guide the process, and ultimately approve process changes that result.
Clearly, there is a lot to the accreditation process, but by following the tips laid out in this article and the last on this subject your company can begin the process of preparing for an accreditation survey. While the process can seem daunting at times it is worth it in the end, not just for its potential to help your organization secure contracts with various payers, but also as a vehicle to help your company improve its business processes over all.
This article originally appeared in the June 2004 issue of HME Business.