The Medicare Modernization Act of 2003 requires CMS to adopt and implement quality standards that HME providers must comply with if they wish to seek reimbursement from Medicare for DME products and services.

Timelines and final requirements are still vague at this time. The standards are only now being developed and won't be ready for public comment until late summer, with adoption targeted for the fall of 2005. CMS then has one year to designate and approve one or more independent accrediting organizations, such as the Joint Commission on Accreditation of Healthcare Organizations (JCAHO), the Community Health Accreditation Program (CHAP) and/or the Accreditation Commission for Health Care (ACHC) to carry out compliance surveys.

While the standards requirement may seem onerous, it does have the effect of helping to level the playing field among providers as they prepare for competitive bidding. In addition, companies that voluntarily adopt quality standards such as those required by accrediting bodies often find that putting effective processes in place improves profits, and that quality really does drive revenue. And it may lead to increased credibility among the public for the industry as a whole.

It's a safe bet that all three of the current standard-bearers will be designated as independent accrediting organizations for the purpose of enforcing the new requirements, but will companies already accredited by these organizations be "grandfathered" into the program? CMS hasn't made a decision just yet, but they are aware of the backlog that will result if both currently accredited and non-accredited providers all need to seek new surveys beginning in 2007. Currently, thousands of Medicare suppliers lack any sort of accreditation, so there is sure to be a log jam no matter what CMS decides. Given that, waiting until the last minute to begin taking steps in the direction of accreditation standards compliance is probably not a good idea. Fortunately, there are some things you can do now that will leave your company well poised to meet the new requirements when they are implemented.

The most far reaching standard of any accrediting body states that the provider shall be in compliance with all local, state, and federal regulations, and it's sure to be one that is adopted by CMS as well. Check to see if your local and state business licenses are up to date. Some states require certain types of employees to hold specific permits or professional licenses in accordance with their job duties – make sure those are up to date as well. The Occupational Safety and Health Administration (OSHA), the Department of Transportation (DOT) and the Food and Drug Administration (FDA) all have regulations that apply to DME providers. It would be useful to assess your company's compliance to those regulations and create an action plan to address the areas where processes fall short.

Current accreditation standards also require compliance to CMS regulations, and it's likely that the CMS version of mandatory quality standards will include them as well; particularly those that pertain to beneficiary rights. At a minimum, take steps now to make sure there is adequate documentation to demonstrate that patients are provided with the required written information; have been informed of their financial responsibilities; are being billed appropriately; and have the opportunity to have their complaints addressed and resolved.

Many accreditation standards require that the company have policies and procedures in place to demonstrate compliance. You can give your company a head start on the accreditation process by updating or creating your company's policy and procedure manual now. Many companies have an employee on staff that is more than capable of creating policies and procedures, but you may find it more cost effective to purchase a manual and edit it to reflect your company's processes. Whichever route you choose, remember that the perfect written description of a procedure it one that is specific enough to meet the standard and instruct your personnel, but general enough to provide your business with the flexibility it needs to run efficiently. It will be at least six months until we know the full specifics of the final quality standards mandated by the MMA, but depending on the size of your company, it can take up to one year to prepare for a successful accreditation survey. In addition, some standards will require that you show at least a brief history of compliance prior to survey. Waiting until the last minute to prepare will only make the process more stressful for everyone. There's no better reason to start taking pro-active steps right now.

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Roberta Domos, RRT, is president of Domos HME Consulting Group in Redmond, Wash. Contact her at (425) 882-2035 or via www.hmeconsulting.com.