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Accreditation/Compliance: Outsource carefully

Accreditation/Compliance: Outsource carefully

Mary Ellen ConwayQ. Does my accreditation prohibit me from outsourcing some of my operational tasks?  

A. The short answer is no, your accreditation does not prohibit you from outsourcing some of your operational tasks, but you’ll need to review your accreditor’s guidelines, as well as the tasks you are planning to outsource, to ensure that you are outsourcing the correct ones. 

There are several operational tasks that you should not consider outsourcing. The first is your sales staff. Your sales staff should be employees of your organization. CMS views the role of independent contractors to be one of a “person who is not under your supervision.” It is thought that an independent contractor might not be representing your business appropriately. Your sales staff does not have to be full-time employees – they can be part-time – but employees, nonetheless. 

Second is your order intake staff. Intake is the time when you are assessing whether the patient meets criteria for service, meeting payer requirements and more. It would be hard to leave that in someone else’s hands who might not have your best interest at heart. You are always responsible for every order you accept and fulfill. Be sure you do not outsource your compliance officer – they must be your employee. You can have a consultant perform a compliance audit, but an employee should be the one that your staff makes aware of compliance concerns and who reports to your board. 

You can always outsource after-hours call services if you need to have licensed staff available for problems and troubleshooting equipment outside of business hours, especially if you don’ t have enough staff to cover on-call and after-hours service. There are several other operational tasks that DME suppliers successfully outsource, such as billing, collections, call center staff, shipping and warehouse services. You should always refer to your DME attorney for further clarification. 

Mary Ellen Conway is a nurse-health care consultant and president of Capital Healthcare Group. She can be reached at  


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