Tools and Tips

• By Michael Lehtola, Lynne Brown
• Jul 01, 2005

With competitive bidding now officially voted into law and set to get underway in early 2007, more than a few providers favor accreditation as a way to level the playing field among potential "bidders." Implementation of minimum quality standards that all HME companies must meet in order to qualify for a share of the Medicare durable medical equipment market, will ensure that companies can't simply reduce the quality of care in order to afford a lower bid. Although timelines for implementation of these mandatory standards by CMS are still a bit vague, more information is slated to be provided in the fall of 2005. Recent surveys of providers show that more than 60 percent are waiting on final guidance from CMS before making a move to meet the expected quality standards. Given that there are currently tens of thousands of non-accredited Medicare DME providers, an accreditation log jam is sure to result when the final rules are made public.

Home medical equipment providers seeking accreditation have three well known accrediting bodies to choose from: the Joint Commission for Accreditation of Healthcare Organizations (JCAHO); the Accreditation Commission for Healthcare (ACHC); and Community Health Accreditation Program (CHAP). All three will likely be approved by CMS to carry out the Medicare surveys, and CMS is consulting with these standard bearers as it adopts minimum mandatory requirements.

The differences among the top three accrediting bodies are minimal in many respects. They share the same basic accreditation standards; they each accredit organizations in three-year cycles; and all three reserve the right to conduct random unannounced surveys at their option. The costs charged for accreditation survey are fairly similar as well.

What can the non-accredited provider do now, while the industry waits for the final implementation of these new regulations? Plenty. Let's take a look at some of the most important standards that providers must comply with in order to be successfully accredited now.

1. Accurate, complete prescriptions. Make sure that you have a complete, accurate, prescription on file for products that require a prescription according to FDA regulations. Ensure that staff members have easy access to a record of the most current prescription before making a home visit so that they can recognize and document discrepancies between the prescription and patient's use of the equipment. Also, make sure that route, dosage, frequency, and length of need are included on the prescription, as appropriate.
2. Preventative maintenance. Define a policy for testing and maintenance of all equipment, and make sure that policy follows manufacturer's recommendations and specifications. If there is no testing or maintenance recommended by the manufacturer you should define a procedure that, at a minimum, calls for the inspection of the equipment on a routine basis.
3. Assess employee competency: Define recurring competency assessments that are required to be completed by staff members on a periodic basis. Choose competencies related to high volume of products provided, or high risk care and services. Use the feedback from your competency assessment program to plan employee training and education activities in response to low scores. And don't forget to document all competency assessment and training activities.
4. Equipment management: Establish clear segregation of clean and dirty equipment areas?in the warehouse, and in staff member vehicles. Make sure your facility has a separate equipment cleaning and repair area. Also remember to correctly store and segregate full and empty oxygen cylinders. And don't forget to monitor the temperature of your enteral storage area, and to check expiration dates on enteral products, tracheotomy tubes, saline solutions, diabetic testing supplies and the like.
5. Emergency preparedness planning. Create a plan by first defining typical emergency scenarios that your company or its clients might face, such as power failures, transportation failures, or widespread staffing shortages. Next, define an employee notification process that includes a call tree, and delineates the responsibilities of managers, supervisors and other employees during an emergency situation. Next, define operational processes, such as who will maintain a priority patient listing, and an off site back-up of computer data. Conduct yearly drills to make sure the plan you have designed will work in practice, and document actual emergencies that may occur so that you can assess the success of the process when things are back to normal.
6. Review personnel files: Make sure they contain all the information that is required including job descriptions, employee performance evaluations, professional licenses as applicable, and W-2 and I-9 information. Document all OSHA mandatory in-service training such as blood borne pathogen training, TB training, and hazardous materials training. Lastly, make sure patient care employee health files containing evidence of mandatory TB testing and hepatitis vaccine waiver or proof of vaccination are up to date.
7. Review patient / client files. Check to see that patient and client files document the completion of a home safety assessment, as applicable, in accordance with equipment provided, as well as a patient functional assessment. Document all patient education that was completed specific to the equipment provided and make sure that updates to the plan of care are completed when the patient's needs change or problems arise.
8. Complete a safety assessment of your facility and vehicles. Make sure that employees have access to the appropriate personal protective equipment such as HEPA masks, gloves, alcohol gel, goggles, and liquid oxygen safety gear. Check to see that eye wash and basic first aid kits are available, both in the warehouse and on vehicles. Ensure that there are fire extinguishers available and that the charge on them is not expired. Assure that appropriate placards are in place on vehicles if they carry more than 1,000 pounds of oxygen at any given time, that oxygen cylinders are stored in DOT approved racking on vehicles, and that "no smoking" signs are in place as required.
9. Review compliance with FDA tracking and recall procedures. Make sure you can respond to a recall on equipment, respiratory medication, or oxygen contents as required by law, in a timely fashion. This is best assessed by simulating a recall on a group of serial numbers and lots numbers from random patient files.
10. Review your infection control program. Your company's infection control processes should be in the form of written policies and procedures that outline a five-point plan, to include:
1. Surveillance — define a process for the collection of data on a specific high risk population or a potential problem area
2. Identification — define a process for an assessment of the data collected to look for trends that require attention
3. Prevention — define operational policies regarding segregation and cleaning of equipment with approved cleaning solutions; include policies that require staff education and training regarding appropriate infection prevention techniques
4. Exposure Control — define a process to appropriately deal with known employee exposures to communicable diseases such hepatitis, tuberculosis, or HIV
5. Reporting — define a process for reporting verified cases of contraction of a communicable disease by patients / clients, or employees, as mandated by state law

This article originally appeared in the July 2005 issue of HME Business.