Becoming a DMEPOS provider enrolled with Medicare is no small feat or undertaking. Whether you’ve started the business from ‘scratch’ or purchased an existing entity, you need to ensure that investment is protected through active and ongoing compliance measures.
To that end, I recently hosted a webinar with Matthew Gruskin, Credentialing Director at Board of Certification (“BOC”) to discuss some of the steps necessary to do so. A copy of our presentation is available here.
Becoming “accredited” is a necessary precursor to being a Medicare Part B DMEPOS provider, and BOC is one of only nine Medicare approved DMEPOS accreditation organizations. Whether it’s through BOC or one of the other eight Medicare approved accreditation organizations, a DMEPOS business’s initial receipt of accreditation is really just a ‘first step’, insofar as if that accreditation is not maintained a DMEPOS supplier will lose their Medicare Part B billing privileges. Medicare’s DMEPOS Supplier Standard #22 specifically requires all enrolled providers to be accredited to receive and retain billing privileges.
A DMEPOS supplier must continue to abide by both Medicare’s DMEPOS Supplier Standards (which the National Supplier Clearinghouse is tasked with enforcing) and its Quality Standards (which accreditation organizations gauge compliance by) in order to stay in its good graces. Accreditation organizations conduct unannounced on-site surveys at least every three years and suppliers must also revalidate their enrollment with Medicare’s National Supplier Clearinghouse every three years, which results in an unannounced Medicare on-site visit.
Here’s a list of some of the top Supplier Standard and Quality Standard deficiencies we experience with our clients upon Medicare or its Accreditation Organization’s on-site inspection, which could jeopardize a DME provider’s ability to do business with Medicare (or worse):
- Failure to maintain adequate employee files: hiring and training records, OIG/SAM monthly exclusion checklists and annual reviews should be contained for each DMEPOS entity employee.
- Likewise, all entities/persons whom the supplier does business with should also be screened against the OIG/SAM exclusion list on a monthly basis, and providers need to ensure they have all required Business Associate Agreements in place.
- Marketing Compliance: a very hot topic historically and as of late, is actively enforced by Medicare and its contractors. Whether its Supplier Standard 11 (compliance concerning direct solicitation of Medicare beneficiaries), or ensuring that any relationships with third party marketers meet regulatory requirements, staying abreast of marketing compliance is a must to maintain billing privileges and out of trouble.
- Policy and Procedure Adherence: whether it’s ensuring the required Complaint Resolution Protocol is abided by (and patient grievances timely logged) or Performance Management Plans/Reports filled out, a supplier needs to ensure these Medicare required documents are ‘living and breathing’.
- Failure to ensure/evidence that the provider’s Medicare DMEPOS patients are aware of their warranty, rental/purchase, and other beneficiary rights.
- Failure to obtain or maintain necessary state licenses for DMEPOS products provided. Each individual stated determines what type of licensure may be required – if any – which is also a product specific analysis.
- Failure to timely update any changes to a DMEPOS provider’s 855s enrollment application – the NSC must be informed of any changes within 30 days.
- Lack of accessibility to the supplier location/compliance with ADA requirements.
Ensure your DMEPOS business’s big book of policy and procedures – the one that enabled it to gain accreditation and Medicare billing privileges in the first instance – is not just gathering dust on a bookshelf, but rather is being actively adhered to, updated, and enforced.
