Accreditation: Time is Running Out
Why providers should start getting accredited and how should they go about doing it? Nobody likes a deadline, especially when the project is big and the clock is ticking. That’s why accreditation is a bit of an elephant in the room when it comes to the HME industry. No one wants to admit it’s there, but it just can’t be ignored. And when it comes to the Sept. 30, 2009 deadline for providers to become accredited in order to continue billing CMS, that deadline isn’t as far off as providers might want to admit. In fact, it might be even closer.
The Time Is NowBesides the fact that the first round of CMS’s competitive bidding program demonstrated that initial estimates for the time needed to simply get accredited was decidedly underestimated, CMS has already announced the next 70 MSAs for the
program’s second round — without a timetable for when that round would actually commence. That “stealth” deadline has left providers in those MSAs not only scratching their heads, but ulcerating over when the other shoe will drop.
“The providers in those 70 MSAs need to be ready,” says Mary Ellen Conway of Capital Health Care Group, who advises that providers in those MSAs should really hit the ground running this month, because accreditation could last between four and six months and CMS will most likely stick to its track record of announcing the dates at the last possible minute.
That first round was incredibly telling, says Ted Jones, president of accreditation consulting firm The IB Network. Only roughly 100 providers were accredited to bid out of approximately 1,500 providers in those 10 initial MSAs. “That is amazing,” Jones says. “I would venture to speculate that the 100 were mostly the big supplier chains…. I don’t know what
happened in the rest of the country and why those providers decided not to participate.”
And that alone is an excellent reason for providers in round two’s 70 MSAs to strike while the metal is hot and get accredited now, consultants and officials from the accrediting bodies say. “Every month that ticks by and we
don’t hear a timeline, that doesn’t mean it’s going to be any more feasible,” says Sandy Canally, president/owner and CEO of consulting firm The Compliance Team. “Message one: Don’t wait.”
“There are thousands of providers waiting to get accredited and only 10 agencies to accredit them — and not every body covers everything,” Canally says.
Regardless of whether or not they are in those MSAs, another reason why providers shouldn’t delay is that they aren’t the only ones in line.
“One of the things providers don’t always understand is how far reaching the Medicare Modernization Act is,” Canally says. “It’s not just the DME providers that are affected. It’s the podiatrists, the PTOT clinics, the orthopedic surgeons, the pulmonologists who might be prescribing nebulizers — So many people are affected by this.”
“That’s why they need to come forward and get accredited,” She continues. “Once all these niches realize it affects them, there’s going to be a real panic, and certainly a bottleneck. Plus, they need to just get it done. It’s not going away. It’s been part of the plan all along.”
And eleventh-hour reprieves don’t seem likely. “Now that we’re in the final hour, Medicare doesn’t feel sorry for you,” Jones says.
What Are the Steps?One thing is for sure, accreditation isn’t simple. “It’s a three-dimensional puzzle,” Jones says.
That said, Pam Gustafson, executive vice president and founder at MCN Healthcare, says accreditation does have a basic flow of steps that providers can follow, which makes the process less mystifying:
• The provider decides to get accredited.
• It reviews the accrediting bodies and picks one that best fits its business in terms of product categories.
• It gets the standards for that organization.
• The provider reviews those standards and ensures it has what it needs to adapt to those standards.
• It decides whether it needs to contract the services of a consultant to help organize and implement the policies and procedures involved in accreditation.
• It decides whether or not it needs to adopt a policies and procedures manual as part of the process.
• It adapts that template to its business.
• A timeline and team is developed to organize the process and work toward implementation.
• When the provider believes it has implemented the policies and procedures it slates a site survey.
•Assuming the provider passes its site survey and achieves accreditation, it might be required to engage in subsequent follow-up meetings.
• At the least, it will need to renew its accreditation every three years, so it must maintain its policies and procedures at all times.
How Long Does it Take?The amount of time it takes to get accredited varies. Estimates can range from four to six months or longer for a provider to get all its ducks in a row. “The bigger your operation and the more ingrained your processes are, the harder it will be,” Jones says.
Canally says that the average time to get accredited with her program is four months. “And we have done it in less time,” she says. “During the first round of competitive bidding we created an accelerated track.”
Canally adds that the Compliance team is providing that track to providers in the next 70 MSAs, as well.
The average staff size for providers working with the Compliance Team is five people, Canally says. “We have everything in our program from one-man bands to regional chains and national companies,” she says. “But we have a lot of mom and pop providers.”
For the Compliance Team, Canally says that the process requires about four hours a week to implement on their end. The approach is to break the task into “digestible chunks” over the duration of the accreditation process so that they can implement and apply those procedures into their operation.
“That lets them absorb the policies and procedures into heir business,” she explains. “We get their buy-in and they can focus on what matters.”
Providers should manage their expectations when getting a realistic idea of how much time the process will take, and if you have the staff bandwidth available, use it, says Morgan Franks of Waltz Pharmacy, which operates an HME
provider business that underwent a smooth, successful accreditation process. “You can’t kid yourself. You have to be realistic and know how much time it is going to take in addition to your job.”
Waltz Pharmacy, based in Maine, conducts a main Pharmacy business and also is a provider of HME items such as bathing aids, daily living aids walking and ambulation products and diabetic aids. It has five locations in Camden, Belfast, Damariscotta, Waldoboro and Pittsfield Main. Plus, Waltz Pharmacy also maintains a home office. All six locations had to be
accredited.
Waltz Pharmacy began its opening conversations with consultants to start its accreditation process in March 2007, and had its site survey in November.
How Much Does it Cost?Accreditation can cost several thousand dollars — $3,000 to $5,000 is a good target experts advise — depending on what a provider needs in terms of consulting, resources and the actual accreditation fees. And those costs might be a key reason why some providers have done their best to ignore looming deadlines.
For instance, a comprehensive policy and procedure manual — a single, but often a key element in the process — can cost as much as $2,000 alone, let alone costs related to implementation, possible consulting, etc. “I am worried about the mom and pop shops,” says Karen Miller of accreditation consultants HealthCom Services. “When you are wearing lots of hats,
accreditation is time away from doing something else… And I think that some of these companies might just barely bring in enough money to pay. But, I do think accreditation is affordable.”
Especially when compared to how much it would cost to hire in-house experts, Jones says. “If you were to hire a compliance office to come in from scratch who had done some ISO 9000 or other accreditation, it’s going to take $50,000 to $80,000 in salary,” he says, adding that still doesn’t incorporate the cost of manual, implementation and accreditation.
In any case cost should be the least of a provider’s concern given the urgency, says Timothy Safley, MBA, RR,T RCP, clinical advisor with accrediting body Accreditation Commission for Health Care Inc. In terms of cost comparison shopping every component varies a little, but ultimately, with consulting, manual, implementation and accreditation costs everything totals up to approximately the same.
How do You Start?Naturally, accreditation can seem daunting at first. “It’s easy to be the deer in the headlights,” Conway says, but adds the key ss just to dive in.
“When they come in they’re scared to death,” Safely says. “But when they come out they say ‘I can do this.’ It’s not that accreditation is hard, it’s the time and work involved initially is what makes it seem difficult.”
Still, those initial jitters are hard to ignore. “Walking into it, it was fear of the unknown,” Franks says. “What do we have to do? Can we get all done?”
But Franks says Waltz Pharmacy set aside those fears and concentrated on the business at hand. It put together an accreditation team that was focused and organized and determined to get it done. “We went into this like we were on a Mission,” Franks says.
Waltz Pharmacy formed a team of five people so that no one or two people had to do everything, Franks says. That team met regularly to plan and adjust in order to stay on top of the processes.
Once you have that team and plan in place, makes sure to diligently work to complete that plan, Franks says. Break that plan into weekly action items so that you have a working checklist that you can use to track and project progress.
And make sure the team sticks to that plan without fail, Miller advises.
Conway says that planning is where a consultant can really help. “A consultant can help you create a timeline, divide the work out, give thoughts on getting additional help, such as educational DVDs or competency programs,” she says.
Then providers need to start reviewing accrediting bodies. They should get a feel for which accrediting body best suits your company’s needs and product range and select one. Not all of them cover the same product categories and have the same expertise or charge the same, Conway notes.
“Find the best accrediting body that fits what you do,” Safely says. “Cost should be the third or fourth thing on the list.”
And don’t stop at just your current product line. Providers should consider how their business might change over the years, Canally says. Providers should consider what product categories or new patients they want to add in the future, and ensure that their business gets accredited in such a way that it will support those products.
Consultants“The very best thing we did was work with a consultant,” Franks says. “It was tough to determine what action items held more weight than other things. A consultant helped us organize and prioritize — and that was the biggest benefit right
there.”
Then talk to your peers, Conway advises. “Go to Medtrade and your state associations and ask other providers who they used and were they happy with them.”
Safely notes that state associations, in general, often provide useful in accreditation: “So join them. Their resources can make this process a lot easier.
In selecting a consultant, Franks advises providers to ensure that they opt for a firm that is prompt in its response to queries. The last thing a busy provider working to get accredited needs is to deal with a firm that is slow to follow-up. “With five stores, there’s a lot going on, and we all have our regular jobs to do,” Franks says.
So, Conway says that the first step in investigating a consultant is to simply call them. “If they can’t return your call or answer questions, it’s likely they’re not going to do it when you’re a customer,” she says.
A substantial track record of accrediting HME providers is also extremely valuable, Franks says, because that consultant will be able to draw upon other experiences and real-life case examples that can provide information that helps provide implement new policies and procedures.
“Call consultants for references of DMEs in your area and ask those references for questions,” Conway says. “That’s the most important thing.”
ManualsRegardless of whether or not a provider works with a consultant, most experts advise buying a polices and procedures manual, which outlines what a provider must do to comply with regulations. Accrediting bodies, such as Safely’s, often provide these manuals, and can walk providers through the steps he says.
That said, this isn’t paint-by-the numbers. The manual is more of a template that must be tailored to the provider business, says Roberta Domos, RRT, owner and president of Domos Consulting Group. It’s a process, rather than an off-the-shelf solution.
“I don’t know how you can do it without a manual,” Conway says. The key, she advises is to select a manual that fits your business, is widely received by businesses similar to yours and, above all, something that works for the accrediting body you select, Conway advises.
Domos advises to select a manual with a proven track record. “If you purchase a policy and procedure manual that has been through accreditation it’s going to cut your development time by two months,” she says. “And if you get a consultant that will cut your time down by half.”
Jones says the “right” manual should also provide the tools a provider needs to become compliant in terms of documentation, such as logs tracking cleaning and maintenance, delivery and receiving, testing and inspection, inventory and safety.
Staff EducationA key element in accreditation implementation is getting staff buy-in, and that means all staff. The policies and procedures a
business must incorporate are wide ranging, and providers must educate everyone on the team, Jones says.
For Waltz Pharmacy this was not a minor task. “We’re not just an HME location,” Franks notes. “We are a primarily a pharmacy. So in order to ensure everyone from the pharmacy business could wrap their heads around something that was being driven by the HME side, that meant we had to train everybody.”
“Train everybody whether you think they need to know it or not,” Franks says. “They should all know why it is important and what the key points are. We took two full days and rented a facility and brought in staff over those two days and went over training on all sorts of things – even how to use a fire extinguisher.
“You don’t think of things like fire extinguisher training as being part of accreditation, but they are,” she explains. “Once everyone sees that it’s for improving the company then you get everyone owning the project and starting working together. So we did that very early on.”
Site SurveysSite surveys are unannounced. Once the provider signals to the accrediting body that it is ready for a survey, the surveyor will come with no warning, Conway says. So, a provider has to have everything ready to go. That can include three or four months of data for the surveyor to review. “The idea is that you are accreditation-prepared everyday, 365 days a year from here on out,” she says.
That lack of warning can seem a little scary, but if a provider has done everything it needs to do, it needn’t worry, Domos says. For example, because the preparation at Waltz had gone so smoothly, Franks says the Waltz accreditation team wasn’t too worried about any what-ifs when it came to the site surveys.
“We were prepared and we kept in the forefront of our process, so we got to the point where we were actually looking forward to the site survey because we were so ready for them,” Franks says.
When the surveys finally happened, Franks says they also discovered that the process wasn’t nearly as grueling as some providers might suspect that it is. “The person conducting the survey was extremely thorough and went through everything we thought we would cover — and she was really polite,” Franks says.
Can site surveys be a flexible process? That depends on the accrediting body and the surveyor, Miller says. It’s an important question, because some providers might innovate efficiencies or work within constraints that might not fit the exact pattern for a process or procedure.
“No DME business is like another,” Gustafson says. “Nothing could be worse than having a regulatory body come in and survey you and the policies don’t reflect what you do.”
Example: a procedure might require the preparation of a given piece of medical equipment to be staged in various sections of a warehouse. Well what if the provider is a two-person operation working out of a small retail space for a limited clientele? What if that provider craftily started handling some elements of preparation in the delivery truck to free up floor space? A surveyor might not find a “check box” that accommodates those limitations or innovations.
In those situations, it is critical for the provider to understand what it needs to do, and work up-front with the accrediting body to determine if and where there are any points of flexibility in those procedures, Miller says.
And, Gustafson adds, the process is not secretive. There are multiple programs available that provide tips on passing site surveys, which is important given how much, as Miller said, those HME/DME provider businesses can vary.
An Ongoing ProcessMake no mistake, accreditation is a process that doesn’t stop. The dialog and process continues for the life of the accreditation, and the frequency of those interactions depends on the accrediting body and the provider’s business.
There is at least a renewal required every three years and some come more frequently than that, Conway says.
“Accreditation is like a new religion,” Jones says. “You have to follow the practices, pay your tithes, and embrace the whole thing, because if you don’t and fake it just to get accreditation, three years later you’re going to lose that accreditation.”
For instance, Canally says that because the Compliance Team’s process is a measured program, they conduct 60-day follows-ups, and then a six-month follow-up, and then are back with providers every year to review, and providers have to continue to score a 90 percent or better during those follow ups in order to meet their certification.
“When we do the site survey and then get the certification, that’s no end to the process,” Canally explains. “That’s only the beginning. We feel like this is a partnership in quality, and we want to help them get on the right track and stay on track.”
Moreover, it aggregates data after accreditation and sends quarterly reports that providers can share with managed care and referral partners — a valuable tool for differentiating a business from the competition.
“It keeps them on-track and they can use that data to show payor partners that they are an exemplary company,” she explains.
And that follow-up has a clear pay-off, Franks says: “In three years, we know that we’ll be at top levels and will have maintained that consistency. You have to keep this an ongoing process, especially for pieces such as training on infection control and safety — they’re another way to remind people to maintain that level of consistency. I feel perfectly confident that we could have a site survey today, and we’d be performing at that level.”
Multiple UpsidesIf anything, accreditation shouldn’t be looked at an obligation with limited benefits. In fact, the process helps providers gain efficiencies and capabilities they might never have considered possible for their businesses — even for small
shops.
“Everything we ask them to do is good business practice,” Canally says. “It’s not about the minutiae… It’s about looking at the whole business.”
“You aren’t creating processes for the sake of creating processes,” Conway says. You’re doing it to improve your business. I’ve never heard anyone say getting accredited was a waste of time.”
For Waltz Pharmacy, accreditation brought streamlined customer communication, increased customer education, proficient customers handling, and overall much improved customer service. Customer education is a particularly important component of that overall improvement Franks adds.
“It is a confusing business and there is so much opportunity for misunderstanding,” Franks explains. “We want to make sure they walk away feeling happy with what they were just billed for.”
Now Waltz communicates important facts to customers in a manner that is faster and clearer. “We are very pleased with our ability to serve our customers now,” Franks says. “I honestly don’t think any of us looked at it as a pain in the neck. We realized that it is going to make our business so much better that it is worth going through. We thought we
did a great job before, but we really do a great job now.”
Another benefit is that the documentation procedures involved in accreditation might create a data treasure trove for providers, Miller says. Because the process involves so much benchmarking, track and trending, providers should mine the resulting data to troubleshoot any problems as well as find opportunities or new efficiencies.
Also, accreditation will help put the industry in a new light, according to Domos who notes that it will help get rid of any of the “bad guys” who have made recent headlines. “Accreditation levels the playing fields so that everyone is meeting the same quality of care,” she says. “Once everyone is accredited for three or four years we will have weeded out companies that don’t have good ethics.”
“Quality helps patients,” Miller says. “That’s the ultimate outcome for all of this.”
“Above everything else, it’s all in how you look at it,” Franks says. “Accreditation should be looked at as a big benefit for your company and well worth doing well.”
This article originally appeared in the March 2008 issue of HME Business.