Funding Focus

Don't Forget Quality Standards

• By Kelly Riley
• May 01, 2010

Lately our industry is overwhelmed by all the changes, revisions, delays and implementations that come out of CMS and its contractors. With these burdens, it is easy to let some less visible regulatory requirements slip through the cracks. Compliance with the DMEPOS Quality Standards may have fallen off the radar screen at your organization. To discover if that is the case, take a minute before reading on to answer the question: How many of the Quality Standards can you recite? When I ask this question, the response I usually receive is related to standards that fall under DMEPOS Supplier Standards, which are different from the DMEPOS Quality Standards. Your organization should be able to demonstrate compliance with both sets of standards.

The DMEPOS Quality Standards contain three sections: Section 1 covers supplier business service requirements; Section 2 addresses supplier product-specific service requirements; and Section 3 contains appendices specific to respiratory care products, rehab and assistive technology, and orthotics and prosthetics.

This article addresses the first section, covering seven distinct areas of your business, each with specific metrics to validate compliance: Administration (6 standards); Financial Management (2 standards); Human Resources Management (3 standards); Consumer Services (3 standards); Performance Management (3 standards); Product Safety (1 standard, with several subparts); and Information Management (1 standard).

Unfortunately, many HME organizations are under the impression that they have met their responsibility if they become accredited. That assumption generally makes sense. In fact, when the final “scaled-back” version of the Quality Standards was released, cutting the document down to 19 pages from 100 pages, key executives from both The Joint Commission and the Accreditation Commission for Health Care stated the standards were not nearly as stringent as those articulated by their accrediting agencies. That may be where the problem lies. Since companies are working to ensure compliance with supplier standards and tougher accreditation standards, they often leave out some “lesser thought of” quality standards. Here are a few vulnerabilities:

Under the Administration requirements, you need copies of ALL manufacturer requirements, warranties and instructions on site. Most companies do a good job of keeping these documents for common items such as oxygen concentrators, beds or wheelchairs. Surveyors know this and will ask for the warranties and instructions for items on your shelves that you forgot you had. Walk through your warehouse and see if you can find such items, then locate the manuals or order replacements.

Under Human Resources Management, the standard says that job descriptions must contain the specific qualifications, training and certifications/licensures where applicable and also the continuing education requirements consistent with the position. I have seen very few job descriptions for respiratory therapists that articulate the continuing education requirements necessary for the renewal of their state licenses. This is different for each state, but is generally 12 hours of approved continuing respiratory care education (CRCE) every two years. Providers should review job descriptions for professional staff and ensure that continuing education language is included.

Under Consumer Services, the standard includes this requirement: If the supplier cannot or will not provide the equipment, item or service prescribed for the beneficiary, the supplier must notify the prescribing physician within five calendar days. Our industry has a long history of simply “getting it done.” If a customer comes to us for a product we don’t provide, we either pick up the phone and call someone, or give the customer contact information so he or she can make arrangements. In order to meet the intent of the standard, consider adding a document to your arsenal of forms. The form should list the customer name; what equipment, item or service your company could not provide; the date this occurred; where you referred him; and of course, the date you sent the form to notify the prescribing physician.

To access the DMEPOS Quality Standards go to: www.cms.hhs.gov to download the PDF. Protect your ability to bill Medicare by reviewing your compliance with the DMEPOS Quality Standards and making any necessary changes.

This article originally appeared in the Respiratory & Sleep Management May 2010 issue of HME Business.