Accreditation, NSC Enrollment, Quality Standards

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• Accreditation, NSC Enrollment, Quality Standards
  NPI Summary

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Accreditation Deadline Update

• CMS has announced that all providers having the
  intention to bill Part B Medicare must be
  accredited by September 30, 2009.
• New suppliers must be accredited by January 1,
  2009 and suppliers who are applying to
  participate in the Medicare program after March
  1, 2008 must supply proof of accreditation with
  their application.
• Failure to achieve accredited status by this date
  will result in revocation of billing privileges
  by the National Supplier Clearinghouse.
• Providers must be accredited by one of the ten
  deemed accrediting organizations.

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Accreditation for New Suppliers

• Providers entering the marketplace after
  September 30, 2009 will need to immediately begin
  the accreditation process.
• According to the January 8 CMS press release,
  suppliers participating in the second phase of
  the competitive bidding program will have to be
  accredited "well in advance of that deadline to
  be awarded a contract with CMS." VGM and all
  industry stakeholders will immediately notify
  affected providers with the Round 2 date.

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Recognized National Accreditation Organizations
for DMEPOS

• Joint Commission on Accreditation of Healthcare
  Organizations
• Community Health Accreditation Program
• Healthcare Quality Association on Accreditation
• National Board of Accreditation for Orthotic
  Suppliers/Board of Certification in Pedorthics
  (merged)
• Accreditation Commission for Healthcare Inc.
• Board for Orthotist/Prosthetist Certification
• National Association of Boards of Pharmacy
• Commission on Accreditation of Rehabilitation
  Facilities
• American Board for Certification in Orthotics and
  Prosthetics Inc.
• The Compliance Team Inc.

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Accreditation Requirement

• Regardless of the accreditation deadline, all
  supplier standards are still in effect. CMS
  directly and through its contractor, the National
  Supplier Clearinghouse (NSC), will still enforce
  and interpret all standards.
• CMS has requested accreditation organizations to
  include a plan that outlines their methodology to
  reduce accreditation fees for small or multiple
  location suppliers.

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Update Proposed New Supplier Standards!

• On January 25, 2008, CMS posted proposed new
  supplier standards and revisions to the current
  21 standards. The public comment period ends
  March 25, 2008. We urge all HME providers to
  closely review and submit comments if
  appropriate!
• On a related matter, new Medicare suppliers
  standards were included in a previous Federal
  Register notice dated August 18, 2006. We will
  review these now.

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The Standards

• (22) All suppliers of DMEPOS and other items and
  services must be accredited by a CMS-approved
  accreditation organization in order to receive
  and retain a supplier billing number. The
  accreditation must indicate the specific products
  and services for which the supplier is accredited
  in order for the supplier to receive payment for
  those specific products and services
• (23) All DMEPOS suppliers must notify their
  accreditation organization when a new DMEPOS
  location is opened. The accreditation
  organization may accredit the new supplier
  location for 3 months after it is operational
  without requiring a new site visit.

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The Standards

• (24) All DMEPOS supplier locations, whether owned
  or subcontracted, must meet the DMEPOS quality
  standards and be separately accredited in order
  to bill Medicare. An accredited supplier may be
  denied enrollment or their enrollment may be
  revoked, if CMS determines that they are not in
  compliance with the DMEPOS quality standards.
• (25) All DMEPOS suppliers must disclose upon
  enrollment all products and services, including
  the addition of new product lines for which they
  are seeking accreditation. If a new product line
  is added after enrollment, the DMEPOS supplier
  will be responsible for notifying the accrediting
  body of the new product so that the DMEPOS
  supplier can be re-surveyed and accredited for
  these new products.

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(26) Surety bond requirements for DMEPOS
suppliers some comments

• Mandated by Congress under the Balanced Budget
  Act of 1997 (BBA), and CMS issued a proposed rule
  to implement it in 1998. Because that rule was
  published more than three years ago and was never
  finalized, CMS has initiated a new rulemaking
  proceeding.
• Require all DMEPOS companies to obtain a 65,000
  surety bond for each of its NPI numbers
  (locations) as a condition of enrollment in
  Medicare.

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• The rule aims to limit Medicares risk from
  fraudulent providers, ensure that only legitimate
  OP practices are enrolled or remain enrolled,
  recoup erroneous payments resulting from
  fraudulent or abusive billing practices, and
  ensure that Medicare beneficiaries receive
  products and services from legitimate providers.
• The 65,000 bond is an inflation adjusted amount
  from the original 50,000 bond CMS proposed in
  1998.

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• The impact of this surety bond could be
  detrimental to small HME providers
• VGM and several other stakeholders have submitted
  comments to the agency.

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Summary of stakeholder comments

• Strongly supported efforts to curtail fraud and
  abuse in the Medicare DMEPOS benefit, but
  concerned the rule will increase providers cost
  and paperwork burdens without accomplishing the
  goals.
• Estimated cost to obtain bond 198 million/year.
  
• CMS analysis suggests added costs will result in
  a reduction in the number of DMEPOS suppliers
  willing to serve Medicare beneficiaries,
  especially in rural areas.

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• Will not eliminate the most insidious type of
  fraudulent operator who initially appears to be a
  legitimate business.
• CMS should exempt providers that have a good
  track record with the Medicare program.
• CMS should exempt rural providers (provided they
  dont otherwise pose risks), to ensure access to
  care for rural beneficiaries.
• Duplicates other initiatives that CMS has not
  fully implemented such as the requirement that
  providers meet quality standards and obtain
  accreditation.

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Surety Bond Suggestions

• Copy the proposed rule and forward to your
  current business insurance agent. The agency may
  be able to write the bond and/or assist you in
  securing an appropriate bonding company (which
  must be from an Treasury approved list) should
  the rule be finalized.
• Bonding companies will require updated
  financials/tax returns.

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• Some surety companies require audited financial
  statements. Investigate now budget accordingly
  for audit/updates and the cost of the bond (2 to
  3 is common, or about 1,500).
• As the proposed rule also suggests reasons to
  increase the surety bond amount for higher risk
  DMEPOS suppliers (not specifically defined) a
  thorough review of past and current Medicare
  issues may be appropriate.

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Quality Standards and Accreditation

• Contract suppliers must meet quality standards
  specified by the Secretary under section
  /1834(a)(20) of the Act
• Quality standards applied by recognized
  independent accreditation organizations
  designated by the Secretary
• Bidding suppliers must be accredited by a CMS
  approved accreditation organization
• Quality Standards will apply to ALL suppliers,
  not just those in bid areas

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Confused?

• DMEPOS supplier standards and Medicare Quality
  Standards are two separate sets of standards.
  Each set of standards relates to different
  aspects of a providers business. Therefore, the
  two processes are not interchangeable. 
• Second, two different groups are responsible for
  ensuring compliance with the two different sets
  of standards. The National Supplier Clearinghouse
  (NSC) is responsible for ensuring suppliers are
  in compliance with the DMEPOS supplier standards.
  The accrediting organizations appointed by CMS
  (such as HQAA, CHAP, ACHC, et al) are responsible
  for ensuring suppliers meet the Medicare Quality
  Standards.

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• Since the two processes and sets of standards are
  different, being in compliance with one set of
  standards does not ensure compliance with the
  other. A suppliers accreditation does not
  automatically mean it has met the requirements to
  bill Medicare as a DMEPOS supplier.
• Some HME facilities are confused about the number
  of site visits theyll receive. Both the NSC and
  the accrediting organizations will conduct site
  visits or surveys to determine a suppliers
  compliance with the set of standards each entity
  is responsible for enforcing.
• Therefore, you should expect to receive a site
  visit or survey from both the NSC and an
  accrediting organization to verify compliance
  with their respective sets of standards.

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• Some of the confusion comes from the fact that
  the NSC is involved in the quality standards
  accreditation process. But the NSCs involvement
  in the accreditation process is limited to
  ensuring suppliers are properly accredited to
  provide the products and services listed on the
  supplier file, and collecting and maintaining
  information regarding supplier accreditation.
• CMS has (finally) established a series of dates
  when all suppliers must be accredited. Therefore,
  suppliers are required to provide the NSC with
  their accreditation information and will complete
  Section 2F of the CMS 855S application form.

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Somewhat simply

• The NSC is responsible for
• The DMEPOS enrollment process
• Ensuring all facilities are in compliance with
  DMEPOS supplier standards
• Maintaining information regarding supplier
  accreditation
• Performing site visits to ensure a practices
  compliance with the DMEPOS supplier standards

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Accrediting organizations are responsible for

• Accrediting facilities based on the Medicare
  Quality Standards for specific products and
  services provided to Medicare beneficiaries
• Ensuring facilities remain in compliance with
  the quality standards
• Conducting site surveys to ensure facilities are
  in compliance with the quality standards

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Quick NPI Review!

• Q Ive gotten a National Provider Identifier
  (NPI). Do I still need to keep my Medicare
  supplier number?
• A Yes, you still need both. Although Medicare
  originally said that the NPI would replace your
  Medicare supplier number, CMS has decided to keep
  the supplier number for use with the DME MACs
  voice inquiry system that you use to check the
  status of claims.

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• Q Im getting ready to apply for a new Medicare
  supplier number. Do I need to have my NPI first
  or can I get that after I get my new supplier
  number?
• A Apply to the National Enumerator first for a
  numberthen use that on your Medicare supplier
  number application. Go to https//nppes.cms.hhs.go
  v/NPPES/Welcome.do for more information and to
  apply.

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• NPI Update! All claims since January 1, 2008
  Medicare now require NPIs to identify the primary
  providers (the Billing and Pay-to Providers) in
  Medicare electronic and paper institutional
  claims (i.e. 837I and UB-04 claims). HME
  companies may continue to use the legacy
  identifier in these fields as long as they also
  use the NPI in these fields.
• We will accept the Legacy, said CMS, but we
  will definitely reject the claim if an NPI is not
  in the primary provider field.
• Beginning March 1, 2008, Medicare Fee-For-Service
  837P and CMS-1500 claims must include an NPI in
  the primary fields on the claim (the billing,
  pay-to, and rendering fields).

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Supplier Number/NSC FAQs

• Q Im expanding my HME and opening a new branch.
  Do I need to get a new Medicare supplier number
  or can I just use my old one? I intend to do all
  my billing out of our original location.
• A Medicare rules dictate that you must have a
  separate number for each location where you
  furnish Medicare covered services, so you do need
  to obtain a separate number for this new
  location. This is the case even though you do
  not plan to bill out of that office. You may
  still bill out of a central location however, on
  the claim form, you must use the appropriate
  supplier number for the location where you
  treated the patient.

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• Medicare does make a few exceptions to this rule.
  You do not need a separate number for locations
  where you do not treat patients (e.g., a
  warehouse or repair facility) or when you are in
  another facility treating the patient (e.g., a
  hospital, skilled nursing facility, etc).

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• Q Im buying an existing HME company. Do I need
  to get a new supplier number or can I use the
  businesss original number?
• A It depends on the kind of purchase you made.
  If you made an assets-only purchase, you will
  need a new number. This is because you will be
  obtaining a new tax identification number (TIN)
  for that new business and will need a new
  supplier number to go with it. Supplier numbers
  are tied to TINs. However, if you made a stock
  purchase of the assets and liabilities, where you
  will be operating the business under the original
  TIN, you do not need a new supplier number.

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• Q I did a stock purchase of a company recently.
  Since Im still operating under the old TIN, do I
  need to notify the National Supplier
  Clearinghouse (NSC) of anything?
• A You must notify the NSC within 30 days of the
  change in ownership. In this case, you would be
  putting in a change notice. However, if you had
  made an assets purchase, you would have to do a
  complete application for a new supplier number.

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• Q I just purchased a company but I dont yet
  have my new supplier number. Can I still treat
  Medicare patients?
• A Yes, but you will have to hold your billing
  until you receive your new supplier number. Be
  aware that you take a small risk in doing this.
  If for some reason you are turned down for a
  number, and cannot correct whatever deficiency
  caused the denial, you will not be receiving a
  new supplier number and therefore you will not be
  able to bill Medicare for these services. You
  will also not be able to bill the patients
  directly. However, this prospect is not likely.
  As long as you provide the NSC with all the
  appropriate documentation they will backdate your
  new supplier number to the date of the sale. At
  that point, once you receive your new number, you
  will be able to bill Medicare for the services
  you provided between the sale date and the time
  you received your new number.

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• Q Im interested in sharing office space with
  another HME (or other DMEPOS Part B supplier).
  Are there any concerns regarding my supplier
  number?
• A Sharing space with another HME is not a good
  idea. The NSC will not approve a new supplier
  number for any location that already has a
  supplier number assigned to it. If you want to
  share office space with a physician, make sure he
  does not have a supplier number that he uses
  occasionally for billing DMEPOS services, or your
  application will be turned down.

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• Q. My supplier number has been deactivated
  because the NSC says I didnt file claims. Since
  I do all my billing out of a central office,
  which Medicare says is okay, whats going on?
• A You probably neglected to use the supplier
  number of the office where the service was
  rendered. If Medicare does not see any billings
  for four quarters from a specific supplier
  number, it will assume that location is no longer
  active and will deactivate that number. While the
  NSC should have given you some notification of
  its intent to do this, that doesnt always
  happen. Be sure to use all your existing numbers
  at least annually.

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Keep Supplier Info Current!

• Providers must keep their supplier information
  current or face being excluded from competitive
  bidding. CMS states "DMEPOS supplier standard
  2 requires all suppliers to notify the NSC of any
  change to the information provided on the CMS
  855S application form within 30 days of the
  change."

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• Maintaining accurate supplier information is
  critical in the face of the impending
  implementation of competitive biddingproviders
  with inaccurate information on their supplier
  files will not be able to participate in the
  competitive bidding process. Suppliers can submit
  a change of information at the NSC Web site
  www.palmettogba.com/nsc.