CMS Lifts Home Health Moratoria in FL, TX, MI & IL

According to the Centers for Medicare & Medicaid Services (CMS), “As of January 30, 2019, there are no active Medicare Provider Enrollment Moratoria in any State or U.S. territories.”  CMS announced Wednesday that the provider enrollment moratoria on home health agencies in Illinois, Michigan, Texas, and Florida have expired. The notice from CMS can be read here.

ACHC is able to expeditiously conduct an Initial Medicare Certification Survey for home health agencies (HHAs) in these states. An organization may apply for accreditation if the following eligibility requirements are met.

The organization must:

  1. Be currently operating within the United States and/or its territories.
  2. Be licensed according to applicable state and federal laws and regulations and maintain all current legal authorization to operate.
  3. Have completed the Medicare Enrollment Application Form CMS-855A and had this form verified by the assigned Medicare Administrative Contractor (MAC), if applicable.
  4. Have established policies and procedures.
  5. Have successfully completed a test Outcome and Assessment Information Set (OASIS) transmission to the state repository, if applicable.
  6. Have met capitalization requirements, if applicable.
  7. Occupy a building in which services are provided/coordinated that is identified, constructed, and equipped to support such services.
  8. Clearly define the services it provides directly or under contract.
  9. Submit all required documents and fees to ACHC within specified time frames.
  10. Be providing home health nursing and at least one qualifying therapeutic service.
    1. The qualifying therapeutic services include physical therapy, speech therapy, occupational therapy, medical social services, and home health aide (Reference in Centers for Medicare and Medicaid Services (CMS) 42 CFR 484.105(f).
    2. A Distinction is a non-qualifying therapeutic service.
  11. Have provided care to a minimum of 10 patients requiring skilled care (not required to be Medicare patients). At least seven of the 10 required patients are receiving skilled care from the Home Health Agency (HHA) at the time of the initial Medicare survey. If the HHA is not able to meet the minimum number of patients required, the initial survey will not be conducted. If the HHA is located in a medically underserved area, they can contact the CMS Regional Office (RO). If the CMS RO determines that the HHA is located in a medically underserved area, the CMS RO may reduce the minimum number of patients from 10 to five. At least two of the five required patients should be receiving skilled care from the HHA at the time of the initial Medicare survey. It is the organization’s responsibility to notify ACHC if it is located in an underserved area.

 

For more information call (855) 937-2242 ext. 457

1st Recipient of ACHC’s Distinction in Hazardous Drug Handling Cites Positive Experience

PCAB-accredited Pharmacy Specialties & Clinic of Sioux Falls, SD, achieved an additional recognition in September when it became the first to receive ACHC’s new Distinction in Hazardous Drug Handling (HDH).

The Distinction in HDH gives ACHC- and PCAB-accredited pharmacies a means to demonstrate compliance with criteria set forth in USP Chapter <800> Hazardous Drugs – Handling in Healthcare Settings. While not set to go into effect until 2019, many pharmacies are taking proactive steps to ensure preparedness with these guidelines aimed at protecting pharmacist and patient safety.

Below, PS&C President Cheri Kraemer talks about her pharmacy’s experience preparing for and undergoing the HDH survey, and offers advice for those who may be considering it.

ACHC: Why did you decide to make your facility USP <800> compliant?

Kraemer: I have always tried to protect my employees from chemicals they work with on a daily basis and I have had a powder room for making capsules and hormones since 2010 so I just decided to finish the entire process since the deadline was July 1, 2018*, and I wanted to be ready.  I would rather be first to act than last when dealing with employee safety. (*The implementation date has since been postponed until December 1, 2019.)

ACHC: What were some of your biggest challenges?

Kraemer: I decided to move the cleanroom, which required a remodel.  We had glass walls and ledges in our old cleanroom, so to make it more efficient for cleaning, we built out a new cleanroom with a hard top, epoxy painted walls, and concave floors.

ACHC: What surprises did you encounter?

Kraemer: The expense; it is always hard to know what things will cost.  So to prepare, I sold my retail pharmacy portion to a local retail chain in order to have money to remodel and do this all properly.  We are compounding only now.  We do less than 5% sterile but I feel ready to do more now that we have gone through all the inspections.  I know many compounding pharmacies are dropping sterile because of the expense to make the changes needed. I want patients in South Dakota and our surrounding states to have access to all areas of compounding.

ACHC: What was easier than you thought?

Kraemer: The hazardous area was quite easy for me because I had a room separated already for many years.  I just needed to vent the hoods outside and designate the area hazardous; separate chemicals; change gowning procedures; and rethink all the various workflow processes.  An example is that you need more equipment. We needed a second ointment mill to put in the hazardous room for topiramate pediatric suspensions made from commercial tablets.

ACHC: What pearls of wisdom might you share with a pharmacy in the beginning stages of preparation for USP <800>?

Kraemer: Consider the hoods you will purchase before the buildout.  We did not make the ceiling in our sterile hazardous room high enough.  It should have been 1 foot taller to accommodate the new BioView hood.  I could not have known that because I did not realize the hood I was getting to put in there was so tall. The hood should be raised up for comfort.

ACHC: How do you feel about ACHC’s approach to addressing USP <800>?

Kraemer: I thought it was very thorough.   Going in to USP <800> certification, the Distinction in Hazardous Drug Handling, I had questions about the extra waste we will create using so many more chemo items.  It was really nice to have Jon Pritchett with ACHC and Brenda Jensen with Compound Consultants to work with regarding some of these details.

ACHC: Do you feel that the Distinction in HDH standards adequately addressed the chapter?

Kraemer: Yes, I was very ready for the inspection after working through the requirements set forth by ACHC/PCAB.

ACHC: Where do you see the compounding industry going? Do you think that hazardous drug handling will continue to be a topic of conversation?

Kraemer: I am ready for HD handling across the board, sterile and non-sterile.  I feel that if I could do this, everyone can do this and should do it sooner rather than later.  It is about safety to your employees, which should be the most important thing to consider when compounding with bulk chemicals and handling other NIOSH list medications.  I feel the sooner this all gets in place, the better for everyone in our industry.

 

Are You Asking the Right Questions About the Cost of DME Accreditation?

“Many companies regret not doing more comparison shopping when choosing their accreditor. Sometimes the cheapest selection ends up costing more in terms of service, additional fees, or resource burdens for the provider,” says Tim Safley, ACHC’s Director of DMEPOS, Pharmacy, and Sleep.

Providers may think they are locked into their current accreditation organization, or that there is little difference among accreditors. “In fact, there is much to be gained by looking closely at how accreditation organizations stack up in terms of understanding an organization, their approach to the survey, the quality of their Surveyors, educational support, reputation within the industry, as well as price and pricing options,” Safley says.

Costs can vary significantly among accreditation organizations. In determining the complete cost of your three-year accreditation, make sure you understand how the AO structures fees by asking the right questions and demanding transparency.

      • Is the accreditation cost a flat rate or based on the size of your organization?
      • Is the accreditation cost a one-time charge at the beginning of the cycle or are there additional annual fees?
      • Are Surveyor travel expenses included?
      • What are the charges if a resurvey is required?
      • Is there a charge for standards initially?
      • Is there a charge when standards are updated?
      • Does the AO offer payment options to help better manage cash flow?

To avoid surprises, make sure all fees are disclosed and detailed in the agreement you establish and consult with your company’s legal counsel if you have concerns.

At ACHC, our pricing is all-inclusive, so you know exactly what you are paying for up front. This price covers your survey as well as all three years of your accreditation. In addition, payment options are available. While there is a $199 charge to obtain standards initially, a $100 discount is applied towards accreditation if your organization contracts with ACHC. There is never a charge when standards are updated. ACHC also allows for additional discounts on accreditation if you are a member of an ACHC partner organization, or attend an ACHC workshop. For further information, contact us at 855-937-2242.

ACHC Extends Well Wishes to Hurricane Victims

The thoughts and concerns of everyone at ACHC are with those in Texas dealing with the horrific aftermath of Hurricane Harvey.  As selfless healthcare workers continue to provide medical aid to patients – often at great risk to themselves – we are hopeful for the safety of providers and their patients.

We will keep those healthcare providers, their families and loved ones in our hearts. Our hope is for a rapid recovery and restoration to normalcy for those who have been impacted during this unprecedented tragedy.  ACHC-accredited providers are encouraged to contact their Account Advisor with any questions or issues.  ACHC encourages anyone who is so inclined to donate to a trusted charity or relief agency involved in helping hurricane victims in Texas.

The Centers for Medicare and Medicaid Service (CMS) has specific resources pertinent to Hurricane Harvey on its website here as well as here

When a natural disaster, extreme weather or emergency occurs that affects providers and the Medicare beneficiaries they serve, special emergency-related policies and procedures may be implemented. For detailed information on these policies and procedures, please see the CMS resources here and here.

 

 

ACHC Surveyor Randy Hughes Shares Expertise on Alternative Delivery Models in HME

At ACHC, our Surveyors are truly experts in their fields. Accreditation Corporate Surveyor Randy Hughes is no exception. Hughes is a registered Respiratory Therapist with over 45 years of experience whose areas of expertise include quality management, operational efficiency and medical gas CGMP compliance. Hughes recently wrote an article  for HomeCare Magazine that examined accreditation considerations for alternative delivery models in HME. Read a condensed version below, or click here to read the full article. Congratulations, Randy!

Changing reimbursement environments, tightening regulatory requirements and managed care are forcing HME providers to develop alternative delivery models for equipment and services. The goal of each has been to provide service more efficiently and effectively while decreasing labor costs.

An important consideration with each model is “who owns the patient?” Who is responsible for providing products to the patient in the appropriate manner? This usually is driven by who bills (and who gets reimbursed) for the equipment or services provided. The “owner” needs to ensure that goods and services are delivered in a manner that meets all accreditation requirements.

The following are examples of alternative delivery models currently in use as well as the associated accreditation implications.

Direct Shipping

  • Not new, but the types of products being shipped have evolved. Oxygen concentrators and CPAP therapy equipment are routinely sent through the mail, so much so that equipment manufacturers have become providers.
  • Accreditation considerations:
    • Documentation of shipping and receipt; patient education; evaluation of safety-related issues and the provision of care process; patient acknowledgement of receipt of patient rights and responsibilities; HIPAA acknowledgement; AOB, etc.

Group patient teaching  

  • New patient “classes” that include group demonstrations, patient education, and interface fitting.
  • Gaining popularity for new and re-instruction CPAP patients and group compressor/nebulizer instructions.
  • Significant increase in staff productivity; patient interactions have resulted in the formation of patient-hosted support teams.
  • Accreditation considerations:
    • HIPAA implications and patient confidentiality
    • Adherence to infection control protocol and practices
    • Assurance that each patient’s documentation is completed thoroughly and accurately and individualizing each patient as patient-specific issues are identified

Sub-contracted delivery

  • The billing entity provides the equipment and supplies while the subcontractor delivers the products. The most common model delivers re-supply items to patients, including reusable and disposable supplies and oxygen cylinders, where new patient teaching and instruction are not required.
  • Accreditation considerations:
    • Well-defined description of expectations from the subcontractor
    • Clear description of the services to be provided, documentation requirements, delivery staff training, orientation and competency and others
    • Written contract detaining the individual responsibilities of each party is required
    • A performance indicator that monitors the services provided by the contracted organization

 Nontraditional oxygen model

  • The goal is to eliminate or minimize resupply visits to a patient’s home after the initial delivery of an oxygen deliver device, usually an oxygen concentrator.
  • The most prevalent examples of this model are the various home oxygen cylinder filling units and the use of portable oxygen concentrators (POCs).
  • Advances in portable technology are resulting in reliable, 3 to 4 LPM continuous flow capability, improved battery life, and continuous-use capability.
  • Accreditation considerations:
    • As long as the equipment is utilized and maintained as required by the manufacturer(s), the same accreditation standards that apply to a traditional oxygen concentrator apply to POCs

Non-clinical ventilator services

  • Today’s ventilators incorporate sophisticated technology to provide multiple modes of ventilation, humidification, and alarm systems in one compact unit. Additionally, the explosion of non-invasive ventilation as an adjunct to or in place of invasive ventilation raises questions as to the need for these patients to receive Clinical Respiratory Services (CRS).
  • Accreditation considerations:
    • Providers who offer ventilator services as non-clinical are considered to be accredited for Equipment Management
    • CRS is not required if the patient does not require ongoing assessment of the patients clinical status via a home clinical assessment ordered by the physician and performed by a licensed clinician

Impact of Technology

  • Significant decline in cost.
  • Will soon see an affordable device that is a POC and oximeter in one.
    • Will include a modem similar to today’s CPAP units that will not only transmit compliance data, it will be an active interface that will facilitate remote troubleshooting, repair, and maintenance
  • Many new questions will be posed from an accreditation perspective.
    • What kind of doctor’s order will be required?
    • What equipment maintenance and documentation is needed?
    • What competency is required for a warehouse employee/delivery driver that remotely accesses a patient’s concentrator for troubleshooting?
    • Is an RT required to teach the patient to self-titrate?

As we move through this continuum, many new questions will be posed from an accreditation perspective. Proactive communication with your Accreditation Organization about what models you are exploring and what impact they have from a standards interpretation perspective will help facilitate this transition.

For more information on ACHC’s accreditation programs or to download ACHC accreditation standards, visit http://www.achc.org, email customerservice@achc.org or call 855-937-2242.

PCAB/USP Workshop featured on Pharmacy Podcast ™

June 16, 2017.  The Pharmacy Podcast (www.pharmacypodcast.com), the nation’s most popular and downloaded podcast on the pharmacy industry, today featured an informational segment about the upcoming PCAB Sterile and Non-Sterile Compounding / USP Compliance workshop to be held July 25-26, 2017 at Fairleigh Dickinson University School of Pharmacy in Florham Park, New Jersey.

This podcast, featuring Pharmacy Podcast founder, Todd Eury, and FDU School of Pharmacy Dean, Michael Avaltroni, can be heard here: //html5-player.libsyn.com/embed/episode/id/5454258/height/360/width/640/theme/standard/autonext/no/thumbnail/yes/autoplay/no/preload/no/no_addthis/no/direction/backward/

The PCAB Sterile and Non-Sterile Compounding Pharmacy workshop provides pharmacy personnel with a comprehensive overview of the accreditation process and a standard-by-standard review of the requirements for sterile and non-sterile compounding. The two-day course is conducted with a personalized approach that delivers valuable insight into the accreditation process.

Since the highly-anticipated release of USP there has been much discussion among pharmacies about the interpretation of these new guidelines—and what that will mean for their operations once implementation takes full effect in 2018. During this workshop participants will examine the new standards and discover practical applications.

This workshop event, priced at $599 for the two-day session–or $499 for the USP segment only–will offer 8.75 ACPE-certified CEs (6.5 CEs for the USP segment only).

To register for the workshops:

PCAB Sterile and Non-Sterile/USP Compliance (2 day, Combined) http://www.accreditationuniversity.com/compounding-pharmacy-workshop.html

USP Compliance (1 day) http://www.accreditationuniversity.com/usp-800-compliance.html

 

Behavioral Health Home Care

Behavioral Health Home Care integrates behavioral health interventions into home care services for patients whose mental illness, substance abuse, intellectual/developmental disabilities make it difficult, or otherwise prevent them from receiving care outside of their homes. Services are provided by a psychiatric nurse and other home care personnel, as ordered by a physician.

Watch the above video to learn more about ACHC’s Behavioral Health Home Care service.

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Ready for accreditation? Contact ACHC at (855) 937-2242 to learn more.

Home Health | Hospice | DMEPOS | Private Duty
Pharmacy | Sleep  | Behavioral Health

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Survey The Expert Podcast: Episode 11 “Behavioral Health Integration”

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[iOS Users]
[5:37]

In today’s Survey The Expert podcast, we’ll be joined by Britt Welch, ACHC’s Behavioral Health Manager. He has over twenty-five years of experience in the behavioral health field and offers his knowledge of clinical practice, community mental health services, and state government.

Episode Highlights:
Behavioral Health integration positively affects patient care

  • Helps to manage patient’s disability
  • Reduces costs
  • Leads to better outcomes

ACHC’s Behavioral Health standards were developed with the integration of care framework

  • 5 services are currently available for accreditation
  • 10 services launching in 2014

Learn more by visiting achc.org or by contacting Britt Welch at (855) 937-2242 ext. 235

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Home Health | Hospice | DMEPOS | Private Duty
Pharmacy | Sleep  | Behavioral Health

Is Your DMEPOS Application Addendum Filled Out Correctly?

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One of the most critical aspects of the ACHC application process that DMEPOS providers must complete is the DMEPOS Accreditation Application Addendum.  The DMEPOS Accreditation Application Addendum is a checklist that the customer must complete to show the equipment and supplies that they are currently billing to Medicare Part B.  It is imperative that the DMEPOS Accreditation Application Addendum matches page 9 of the current 855S enrollment application for each Provider Transaction Access Number (PTAN) or Medicare Provider Number.

During the on-site survey, our Surveyors use the completed DMEPOS Accreditation Application Addendum to determine if that the specific location has appropriate inventory and is equipped to provide each product code to patients in a timely manner.   For organizations with multiple locations/PTANs, each location should have its own unique DMEPOS Accreditation Application Addendum even if the equipment and supplies provided is the same.

Before the ACHC survey is completed, the surveyor will sit down with a representative from the organization to review the DMEPOS Accreditation Application Addendum and ensure that the correct product codes have been selected.  The ACHC surveyor and representative will sign and date the form acknowledging the codes that will be reported to Medicare.  When the organization’s Accreditation Advisor issues the approval, they will include a copy of the signed DMEPOS Accreditation Application Addendum with the documentation.

ACHC strongly encourages all of our customers to carefully review their DMEPOS Accreditation Application Addendums when submitting their application and also while on-site with their ACHC Surveyor. Renewing ACHC customers should complete a new DMEPOS Accreditation Application Addendum for each three-year accreditation cycle.

To verify the product codes that you are currently accredited for, please log into your Customer Central account. If you have any other questions or need any assistance in completing a DMEPOS Accreditation Application Addendum, please contact your organization’s Accreditation Advisor at 855-YES-ACHC (937-2242).

Home Health | Hospice | DMEPOS | Private Duty
Pharmacy | Sleep  | Behavioral Health

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About the Author:

matthew_hughesMatt Hughes is the Director of Business Development & Customer Service. His primary functions are working with current corporate customers along with identifying new opportunities to help grow ACHC.  He works closely with state associations and other member organizations throughout the country.

Effects of the Federal Government Shutdown

With the collective eyes of the nation focused on the federal government during this shutdown, ACHC wants to reassure our customers that this does not delay scheduling of on-site surveys, awarding non-deemed accreditation, or submitting our findings and recommendations for deemed status to the CMS Regional Offices. Agencies with deemed status who are due for renewal during the shutdown will not be affected; those facilities with a CCN are still able to bill Medicare.

The shutdown has resulted in many CMS Regional Office (RO) employees being furloughed; these employees are the ones who determine whether or not to accept our recommendation of surveyed organizations into the Medicare program. Applications will be processed when the government reopens, but it should be anticipated that the time to complete these may vary by region depending on staffing and workloads, and that Medicare reimbursements may be delayed.

It should be noted that State licensure functions and enforcement activities are not constrained by the federal government shutdown.

Click here to read the following memo from CMS that provides detailed information on survey and certification activities during the government shutdown.  As always, your ACHC Accreditation Advisor is available to answer all of your questions. Call (855) YES-ACHC [937-2242].