The accreditation simplification movement that is sweeping through healthcare evaluation circles today has had a profound impact on all sectors of our healthcare delivery system. Indeed, in many important ways, the focus has shifted from a monolithic, one size fits all approach to accreditation, to more nuanced customizable programs that help healthcare providers alter their everyday business operations to meet specific healthcare sector patient care quality measures.
In recent years, as a way of urging these reforms forward, the Centers for Medicare and Medicaid Services (CMS) has adopted plain language, product-line and service specific, accreditation quality standards for the durable medical equipment, prosthetics, orthotics, supplies (DMEPOS) industry.
Indeed, no sector of our healthcare delivery system has felt the effects of accreditation simplification more acutely than the DMEPOS industry. Competition between the various CMS “deemed” private sector accreditation organizations has not only helped streamline and simplify the accreditation process, it has effectively lowered implementation times and all associated costs across the board. This is especially true for sleep center DMEPOS accreditation; bringing benefits to both provider organizations and patients alike.
Let there be no misunderstanding, sleep center DMEPOS accreditation is not the same as the accreditation process for a diagnostic sleep center facility. Whereas facility-wide accreditation looks at the entire organizational structure and the daily operations that are needed to conduct successful sleep studies, sleep center DMEPOS accreditation is much more narrowly focused on the activities surrounding patient set-up and usage of a limited number of product types; most notably CPAP and Bi-PAP devices.
What follows are some caveats that I believe should be closely adhered to in order to assure that sleep DMEPOS accreditation becomes synonymous with the exemplary care that every patient deserves:
1. Medicare’s DMEPOS Supplier Standards as well as product specific accreditation quality standards must be met in order to maintain a facility’s Medicare billing privileges.
2. Written policies for sleep center DMEPOS need to be understandable to all staff members; not just administrators and compliance officers.
3. Policies and Procedures should reflect an operations perspective when addressing specific business functions such as: Administration, Human Resources, Equipment Management etc. By formulating policies according to the functions and tasks of the DMEPOS department it makes it easier for the staff to utilize it as a true resource.
4. Comprehensive instruction on Plans of Care and the close monitoring of product use compliance through diligent follow-up procedures brings with it many patient care benefits.
5. Patient care services are best evaluated by experienced sleep professionals. These professionals must be properly credentialed, and participate in a continuous education regimen.
6. Sleep DMEPOS staff should be able to demonstrate a thorough knowledge of the full range of products as well as their set-up and delivery requirements.
7. As experts in Equipment Management- sleep DMEPOS professionals add value to the patient’s plan of care goals.
8. CPAP/ Bi-PAP devices have built-in compliance monitoring functions that are designed to track compliance and give feedback to the sleep physician.
9. Sleep DMEPOS equipment experts often do the most thorough job of product instruction.
10. Sleep DMEPOS departments should demonstrate expertize in staff training in the exercise of universal precautions to prevent cross-contamination from blood or other bodily fluids.
11. Cleaning, storage and maintenance of equipment is critically important as an infection control measure. E.g. Using appropriate disinfection techniques. Proper hand washing.
12. Patient follow-up is an integral part of the DMEPOS accreditation process and is a special area of interest during the accreditation on-site evaluation or survey visit.
13. Inventory tracking is an important component of the accreditation process as a measure of recovery readiness in the event of a product recall. (A good inventory tracking mechanism also helps maintain profitability by preventing thief or product “shrinkage”.)
14. Medical Record reviews are an important aspect of the sleep DMEPOS accreditation process. During an on-site evaluation/ survey while looking at patient records we want to see documentation of all patient interactions that transpired as well as the LCD/insurance requirements of the billing provider.
New rulings by CMS are happening all of the time and they often change what is required of sleep professionals; to the point where keeping up with the ever-evolving world of government regulatory matters becomes a critical business function. Case in point, Medicare Part B now requires that beneficiaries return to their doctor for a CPAP compliance (usage) test 60 days after set-up, but before 90 days from the dispensing date.
Another rapidly evolving arena that is affecting diagnostic sleep center business models is the status of home sleep studies. Now that home testing is CMS reimbursable, patient safety and the appropriateness of the sleep study device being used in a home environment must be taken into account.
Given the general leveling effect that CMS’ product-line and service specific quality standards have brought to the DMEPOS accreditation world, it is easier than ever for diagnostic sleep centers to meet these nettlesome challenges. Much of the credit for these advancements should also go to the emergence of the new era of healthcare accreditation simplification. Sleep DMEPOS professionals can bank on it.
Sandra C. Canally, RN is the Founder and President of The Compliance Team, Inc., a CMS approved accreditation organization with deeming authority for DMEPOS. In addition, her firm offers a full line-up of proprietary Exemplary Provider™ accreditation programs including ones for: Diagnostic Sleep Center, Infusion/ Specialty/ and LTC Pharmacy, Critical Access Hospital, Rural Health Clinic, Physician Practice/ Medical Home, Long Term Care, Home Health/ Hospice Agency, Private Duty Homecare, Ocularist/ Anaplastologist.