The following organizations have been selected as accrediting agencies for DMEPOS suppliers.  Please remember that all DME Suppliers must be accredited by Sep 30, 2009. 

The Joint Commission
601 13th Street NW, Suite 1150N
Washington DC  20005   (630) 792-5000

National Association of Boards of Pharmacy (NABP)
1600 Feehanville Drive
Mount Prospect, IL  60056    (847) 391-4406

Board of Orthotist/Prosthetist Certification (BOC)
7150 Columbia Gateway Drive, Suite G
Columbia, MD  21045    (443) 539-3810 or (877) 776-2200

The Compliance Team, Inc.
905 Sheble Lane, Suite 102
Spring House, PA  19477    (215) 654-9110

American Board for Certification in O&P, Inc. (ABC)
330 John Carlyle Street, Suite 210
Alexandria, VA  22314    (703) 836-7114

The National Board of Accreditation for Orthotic Suppliers
401 N. Michigan Avenue, 22nd Floor
Chicago, IL  60611    (888) 463-4011

Commission of Accreditation of Rehabilitation Facilities
4891 E. Grant Road
Tucson, AZ  85712    (520) 325-1044 or (888) 281-6531

Community Health Accreditation Program
1300 19th Street NW, Suite 150
Washington, DC  20036    (202) 862-3413

HealthCare Quality Association on Accreditation
217 West 4th Street
Waterloo, IA  50702    (866) 909-4722

Accreditation Commission for Health Care, Inc.
4700 Falls of Neuse Road, Suite 280
Raleigh, NC 27609    (919) 785-1214

Several of us at Dr. Comfort have spent the week talking to companies that have been
qualified as Accrediting firms. We learned quite a bit over the week and will provide you
with regular updates to de-mystify this beast and break it down into reasonable bites.
Here’s a snapshot of what we have learned about the accreditation process as mandated in
the 2003 Medicare Modernization Act:

• Accreditation is not going away – all attempts to get Podiatrist’s offices exempted
from this standard have failed. There will be no ducking this one for anyone
billing under Part B.

• From start to finish, the accreditation process will take from 3-7 months – we will
explain more of the specifics in upcoming faxes. If you back up from the
designated date of 9/30/09 and you look at the far end of the range, then you need
to start your process no later than the end of Feb09. You also don’t want to be in
that last group – there is going to be a mad scramble at the end.

• You need to take this seriously – failure to achieve accreditation by 9/30/09
means that you will not be able to bill Medicare for provided services. Not good.
The person running your offices needs to dedicate some time to this.

• Accreditation is generally by facility – it looks like discounts may be provided for
multi-location practices. But each office/facility is treated separately.

• The cost for accrediting a single facility is between $2,650 and $3,000 – this will
be good for a 3-year period. While the initial outlay may be painful, annual costs
should be less than $1,000 per year. It won’t take too many pairs of shoes to
make that back.

Dr. Comfort will become affiliated with one or more of these accrediting bodies to
customize a manual or procedural guide that will help each of you. In addition, we will
use our buying leverage to provide you with a better price.

What Does It Mean To Be Accredited Per the CMS Guidelines?
In the 2003 Medicare Modernization Act, CMS implemented new standards of patient
care and fraud protection over the entire orthotic, prosthetic, pedorthic and DME market.
As noted in previous Dr. Comfort updates, these new standards require all DME suppliers
to submit to mandatory facility accreditation – and CMS is going to rely on independent
organizations to verify compliance against established Medicare Quality Standards.
The Standards are grouped into five categories. Accreditation decisions are based on
the degree of conformity with each Standard. The categories are:

• Organizational Standards: these relate primarily to the organization’s legal
status, corporate governance and administrative structure.
• Patient Care Standards: the standards designed to support the delivery of high
quality patient care – and to ensure that patient needs are met.
• Performance Management Standards: the standards associated with the
assessment and improvement of the delivery of patient care services.
• Facility Safety: standards relating to the physical location of patient care
• Supplier Compliance: standards relating to the compliance with the requirements
of CMS

Each of these categories contains a series of standards (from 10 to 20) that require
compliance. We will delve more deeply into each one of these categories to get after the
specific requirements of each. An initial read of these specific requirements suggests,
however, that if you are already running your organization in an efficient manner and are
focused on continuous improvement in patient care and service, you should be in pretty
good shape. It may take a bit of time to document all that you do, however.
Our discussions with the accrediting sources are progressing well – we fully expect to
provide Dr. Comfort accounts with a stream-lined process and, more importantly, a
discounted price.

Accreditation Will Require Some Work to Pull All the Data Together
Recall that last week we talked about the overall guidelines that will be reviewed for compliance by the accrediting body. One of the accrediting organizations (ABC) has broken down the guidelines into 5 sections – others use fewer.
The first section is entitled Organizational, Governance and Administrative Management Standards. The 8 major topics within this standard are:

The organization is a legally constituted entity … and complies with all … laws

The organization makes full disclosure of ownership….

The organization has a governing body (or designated person) that sets policy and has overall responsibility for the organization

Adopts a mission statement and sets organizational goals and objectives

Adopts written policies/procedures for orderly conduct of business

The governing body is responsible for staff appointment and the delivery of patient care services

The organization shall only provide those pedorthic and other items as disclosed on their current CMA-855S application

Policies, procedures and controls are reviewed at least annually

The organization complies with the provisions of HIPAA

The organization complies with provisions/requirements of CMS Supplier Stds

The organization complies with the provisions of the ADA

Financial records shall be accurate, complete and current.
As you re-read the above list, you will most likely agree that you already have these items in place. In fact, it would be difficult to run an effective business operation without covering these items.
Next week we will go over Patient Care and Management Standards. If you want to peek ahead, feel free to go to the ABC web site at www.abcop.org. Future discussions will also include references from other accrediting sources.

Recall that last week we talked about the guidelines related to the first section that ABC
Accreditation will look at – this week, we will summarize the second section.
The second section is entitled Patient Care and Management Standards. The Patient
care area addresses the 7 essential components designed to support the delivery of highquality
patient care and to ensure that patient needs are met. The seven essential
components are areas that I’m sure you address in your everyday work – these are:
1) Policies and procedures, 2) Patient management protocols, 3) Physician interaction and
communication, 4) Patient records, 5) Patient rights, 6) Patient and family education, and
7) Patient follow-up care
These seven essential components are weaved throughout the 10 targeted questions:
• … the professional staff provides quality clinical care to patients according to
generally accepted professional practices
• There are written patient management policies … at each physical location
• Patient care service is provided under the direction of certified personnel acting
within the scope of their practice.
• Appropriate services are available to respond to patient emergencies that may
occur in the facility – this includes first aid, CPR, etc.
• Referrals, consultations and all other communications with the referring
physician are documented in the patient’s clinical records…
• There is a patient record system that permits prompt retrieval of information, are
uniform and legible, and are updated accurately in a timely manner – only
accessible to staff on a need to know basis.
o There are lots of sub-points in this particular section.
• Patient rights are supported – each patient is treated with respect, dignity and
consideration.
• Performance and services are assessed through patient satisfaction surveys.
• The patients and caregivers are provided with education that enhances the
benefits of pedorthic care.
• Patient follow-up care is consistent with services provided – the patient’s lack of
compliance is also so noted in the records.
Next week we will go over Performance Management and Improvement Standards.
If you want to peek ahead, feel free to go to the ABC web site at www.abcop.org. We
are still working with many of the accrediting bodies to develop a cost-effective solution
for you – more to come on that.

Performance Management and Improvement Standards.  Accrediting sources will look for a proactive process to assess and improve the quality of patient care.  The essence of this standard is:

There are 6 primary areas that will be reviewed by the accrediting source

These areas may pose some problems for the average office – while you certainly do the above on a regular basis, you will have to show some documentation of these actions.

If you want to peek ahead, feel free to go to the ABC web site at www.abcop.org.

Facility and Safety Management Standards.  As stated in some of the literature on this topic, health care settings are inherently risky environments.  Accrediting sources are going to be looking for adequate and well-equipped space in your facilities including 1) facility safety, 2) safety management and 3) environmental safety.

Here we go….