Comment period for draft quality standards nears

Sunday, November 20, 2005

WASHINGTON - In 24 pages of draft comments, AAHomecare blasted CMS's proposed quality standards, calling them "overly prescriptive" and similar to existing laws and regulations.

The association plans to finalize the comments and submit them to CMS. The draft, among other things, recommends 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 will accept 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 categories.

All providers will have to meet the standards eventually, starting with providers in the 10 cities where the CMS will kick off national competitive bidding in 2007.

AAHomecare also believes the standards may 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.

Other points that AAHomecare aims to bring to CMS's attention:

- Timeline and grandfathering: CMS needs to make sure that providers in the 10 MSAs have enough time to get accredited before bidding begins. Also, how will accredited providers be grandfathered?
- Enrollment: CMS needs to clarify the roles of different entities that will have oversight authority for providers, like the National Supplier Clearinghouse.
- Consistent terminology: CMS needs to develop definitions for "licensed," "credentialed" and "qualified."