AAHomecare blasts quality standards
WASHINGTON - AAHomecare blasted CMS's draft quality standards in late November, calling them "overly prescriptive" and similar to existing laws and regulations. The association submitted 24 pages of comments to the agency.
The comments recommend, among other things, that CMS eliminate the product specific standards. Instead, AAHomecare suggests that providers be allowed to implement internal policies and procedures that are consistent with current standards of practice and state and federal requirements.
"As written, many of the standards leave little room for the provider to exercise judgment in the manner it furnishes service," read the comments, signed by President Kay Cox. "Standards should establish the benchmark that a provider must meet but should not be so specific that they dictate care or service."
Additionally, "CMS should reconcile the standards with state, federal or local laws or regulations," the comments continue. "As written, a number of the standards are duplicative of other requirements. This results in burdensome and unnecessary documentation."
CMS accepted comments on the quality standards until Nov. 28. The standards, released for comment in late September, are divided into two groups: business quality standards and product specific service requirements for 14 product categories. All providers will have to meet the standards eventually, starting with providers in the 10 cities where CMS will kick off national competitive bidding in 2007.
In its comments, AAHomecare also pointed out that the standards might place an undue burden on small providers. The financial management requirements, for instance, require providers to use an accounting method that's more commonly required of publicly traded companies.
Jeff Wills, chairman of AAHomecare's HME/RT Council, which helped the association craft its comments, said generally accepted accounting principles, or GAAP, don't make sense for a company like his. The Oklahoma City-based Canadian Valley Medical Solutions employs 85 people and is privately held.
Another financial requirement that concerns Wills: the possibility of having to conduct yearly audits. "For my company, a full audit would cost an estimated $75,000 a year," he said.
Finally, having to notify CMS and accrediting organizations of "potential adverse financial operations" also concerns Wills.
"I'm not even really required to notify my lending institution of that," he said. "As business goes up and down, there may be times when we're moving through financial challenges. I'm not even sure what they would do with that information. How would they measure (adverse financial operations)?"
AAHomecare also stated:
CMS needs to make sure that providers in the 10 MSAs have enough time to get accredited before national competitive bidding begins.
CMS needs to clarify the roles of different entities that will have oversight authority, like the National Supplier Clearinghouse.
CMS needs to develop definitions for "licensed," "credentialed" and "qualified.