The Bottom Line: Quality Standards and Accreditation
By Kathy Dodson, AOPA Government Affairs Department

While there has been quite a bit of publicity about these two topics, there is still confusion about how they differ and when your facility must comply. If that weren’t enough, CMS released a revision to the quality standards. Here’s the bottom line on how each of these regulations will affect your facility.

Quality standards
In 2003, the Medicare Modernization Act mandated that CMS implement quality standards. Even though quality standards are often discussed along with competitive bidding, they are two separate things. Quality standards deal with the quality of care provided to Medicare beneficiaries. These differ from the Medicare supplier standards, which speak more to office setup, types of care provided, liability and other administrative issues.

Also, while Medicare supplier standards are enforced by the National Supplier Clearinghouse through its contractor, Overland Solutions, quality standards will be enforced through the accreditation process.

To bill Medicare for O&P care, you must meet both sets of standards, although CMS is phasing in the quality standards requirement.

Accreditation: a long time coming
MMA also mandated that facilities be accredited in order to bill for O&P services. But it wasn’t the first time accreditation was mandated; in the Benefits Improvement Act of 2000, accreditation of facilities by either ABC or BOC was required for prosthetics and certain custom-fabricated orthoses. Because CMS never created regulations to implement this requirement, it has not been enforced.

Now that’s changing. Because of MMA requirements, CMS must now require accreditation for all O&P care. It has identified a number of entities that can accredit O&P facilities, the best known in our field being ABC and BOC. Both of these groups, along with the other approved accrediting agencies, have amended their accreditation requirements to bring them into compliance with the quality standards.

Common questions
Is accreditation required now? When your facility will be required to become accredited varies, depending on whether or not your facility already has an NPI number and is enrolled to provide Medicare services.

Facilities that already have an NPI and Medicare number have until September 31, 2009 to become accredited. However, new facilities, including new branch offices of existing facilities, must become accredited before they can submit their application to bill Medicare.

The bottom line? Sooner or later, your facility will have to be accredited to bill for O&P services, and you must meet the new quality standards to become accredited.

Where can I find the quality standards? You can obtain a copy of the current standards by going onto the CMS Web site, http://snipurl.com/211km, scrolling down and clicking on the document “New Quality Standards for Suppliers of Durable Medical Equipment, Prosthetics, Orthotics, and Supplies [PDF, 90KB]—posted 8/15/06.” These are the quality standards that the accrediting bodies are using currently.

However, there are some revisions pending. At press time, CMS had put out a new version of the standards, with a comment deadline of March 18. (You can find this version at http://snipurl.com/211kv. Click on the item titled “DMEPOS Accreditation Standards for Public Comment—February 2008.”)

AOPA provided comments to CMS on these proposed standards. Now that the comment deadline has passed, CMS will consider the input it has received and will issue a final version.

At that time, AOPA will publish a notice in its AOPA In Advance e-mail newsletter giving further information on how to obtain training on compliance.

Do all the standards apply to O&P? The quality standards are broken down into sections:

•    Supplier Business Service Requirements
•    Supplier Product Specific Service Requirements
•    Appendix A: Respiratory Equipment, Supplies and Services
•    Appendix B: Manual Wheelchairs and Power Mobility Devices, Including Complex Rehab and Assistive Technology
•    Appendix C: Custom Fabricated and Custom Fitted Orthoses, External Breast Prostheses, Therapeutic Shoes and Inserts, and their Accessories and Supplies; Custom-Made Somatic, Ocular and Facial Prostheses

All DMEPOS suppliers, including O&P, will have to be in compliance with the first two sections. Of the appendices, only Appendix C will apply to O&P. To find these sections and appendix C, go to http://snipurl.com/211km.

Kathy Dodson is the senior director of government affairs for AOPA. Questions? Call (571) 431-0810 or visit www.AOPAnet.org.