January 14, 2010

This article is based on Change Request (CR) 6750, which implements two provisions from the Home Health Agency (HHA) Prospective Payment System Final Rule (CMS-1560-F). The first provision requires an HHA whose Medicare billing privileges have been deactivated to undergo a State survey or obtain accreditation from a CMS-approved accrediting organization prior to having its billing privileges reactivated. The second provision holds that an HHA may not undergo a change of ownership or transfer of ownership if the effective date of the change or transfer occurs within 36 months of: (1) the effective date of the provider’s enrollment in Medicare, or (2) the effective date of the last ownership change or transfer for the HHA. The provider must instead enroll as a new HHA, undergo a State survey or obtain accreditation from a CMS-approved accrediting organization, and sign a new provider agreement.

Click here to read the article.

December 18, 2009

For deemed hospice providers: CMS publishes an advance copy of the hospice sections of the State Operations Manual, which are effective 9.18.2009. This includes CRITICAL information about how CMS handles a hospice change of address, including move after a certification survey.

Click here to read the CMS memorandum.

New Medicare Requirements Take Effect for Suppliers of Medical Equipment and Supplies New Standards Prevent Fraud and Promote Quality Care

The Centers for Medicare & Medicaid Services (CMS) today issued a final reminder about new requirements for most suppliers of durable medical equipment, prosthetics, orthotics and supplies (DMEPOS) to meet new quality standards by Oct. 1 and obtain a surety bond by Oct. 2 as required under Federal law. These new supplier enrollment requirements will help to prevent fraud in Medicare and ensure that people with Medicare get high-quality medical items and services from qualified suppliers.

While the majority of Medicare beneficiaries will not be impacted by these new rules, people with Medicare should ask their suppliers if they are approved by Medicare to continue to ensure that Medicare will pay their claims. Suppliers must post notice if they are not accredited by Medicare or have the beneficiary sign an Advanced Beneficiary Notice (ABN) before they are charged for the items or service. Beneficiaries who need to find a new supplier can go to the "Find a Supplier" page at www.medicare.gov or call 1-800-MEDICARE.

To read the entire CMS fact sheet issued today (October 1, 2009) click here.

More information about the accreditation and surety bond requirements for DMEPOS suppliers can be found at www.cms.hhs.gov/MedicareProviderSupEnroll.

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CHAP MEMORANDUM

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TO:	COMMUNITY BASED CARE PROVIDERS HOLDING OR SEEKING ACCREDITATION
FROM:	TERRY A. DUNCOMBE, PRESIDENT/CEO
SUBJECT:	CHAP UPDATES AND TIMELINES
DATE:	SEPTEMBER 14, 2009
It has been several months since my last update, and I am delighted to announce that CHAP has made significant progress on several fronts. Home Health and Hospice: We have met our goal of being able to promise site visits within 1- 4 months of self study submission, and confirmation of all other ?readiness? factors. As always, CHAP will schedule site visits to organizations that have submitted a complete self study, and notified us of readiness, in the date order this notification is received. Here is how you can help ensure the best service from us: Ensure that you use the self study tools and process to not only develop structure but also process for home health and hospice accreditation standards. Ensure that you have forwarded a copy of your ?855 review completed? letter from your fiscal intermediary (for new Medicare providers) and your OASIS test transmission report (new home health providers only). These documents must be on file with CHAP before we can schedule your site visit. Ensure that you meet minimum census requirements and notify us in writing. For deemed status, home health must have served 10 patients and have 7 active at the time of the site visit, and hospices must have served 5 and have 3 active patients. These are not required to be Medicare patients. Unfortunately, we have encountered a number of occasions in which organizations stated they were ready for site visit, but upon arrival, the required census was not in place. In these cases, we cannot complete your site visit, but will bill you for the site visit days and you will be moved to the bottom of our site visit schedule list. Please notify us in writing of address, telephone number, and/or other significant changes within your organization. Close communication with CHAP through your Customer Relations Representative will help ensure we have correct and complete information for your organization. Site visits can occur at any time for organizations seeking deemed status. Once you have notified us of your readiness, your organization will be scheduled for site visit and you must remain ready or notify us in writing that your organization needs to be rescheduled. HME and Pharmacy: The deadline is now! DMEPOS providers who submitted self studies before September 1, 2009 WILL have their site visit completed, and if successful in achieving accreditation, WILL have their information transmitted to CMS. Please remember that CMS requires a separate PTAN number for each service delivery/practice location address. CHAP will continue to accept new applications and schedule unannounced site visits for all DMEPOS providers seeking accreditation. Visits are provided at any point within 1-2 months of submission of the self study. Process Improvement: Satisfaction - Self studies for all accreditation services types now are submitted through our web based application. Your Customer Relations Representative will set you up as we send your executed contract. All required documents can be submitted electronically as an attachment. Timeliness - Our Board of Review is now reviewing site visit reports the month following the site visit; this is increased from six times per year. Along with other actions we have underway, we are intent on providing your post site visit accreditation process in 90 days or less. Efficiency and Automation - Our web based Plan of Correction toolset is almost ready for launch, as we implement our new policy requiring POC?s from all providers. For those that missed the web training to improve structure and guidance on understanding and resolving problems, the presentation is available for review on our website. Training and Education - We heard your concerns and are working to meet your needs and we continue work on development of an education series. Please keep an eye on our website for announcements. The entire CHAP Team thanks you for the opportunity to be of service to you, to further quality improvement in community based care and we greatly appreciate your continued support and patience as we make changes necessary to improve our service to you.

Medicare suppliers of durable medical equipment, prosthetics, orthotics and supplies (DMEPOS), unless exempt, must be accredited and secure a surety bond by October 1, 2009 and October 2, 2009, respectively.

What you need to do if you have already obtained DMEPOS accreditation from an approved accrediting organization

If you have already been notified by an approved accrediting organization that each of your practice locations have been accredited, you do not need to take any additional actions to notify the National Supplier Clearinghouse that your DMEPOS supplier practice locations have been accredited.

What you need to do if you are in the process of being accredited

The Centers for Medicare & Medicaid Services (CMS) encourages all DMEPOS suppliers currently in the midst of the accreditation process to correct all outstanding deficiencies on your accreditation report so that a site visit or accreditation decision can be rendered by the October 1, 2009 deadline. Moreover, DMEPOS suppliers who obtain accreditation after September 1, 2009 but before October 1, 2009, should submit proof of accreditation to NSC via submission of an amendment to their CMS-855S (Medicare Enrollment Application). This form is available on our website. Sections 1, 2 and 15 or 16 should be completed. In particular section 2G should provide the accreditation information.

Note: If you have problems accessing any hyperlink in this message, please copy and paste the URL into your Internet browser.

Suppliers May Choose to Voluntarily Terminate Enrollment If They Do Not Plan To Comply

Medicare suppliers of durable medical equipment, prosthetics, orthotics and supplies (DMEPOS), unless exempt, must be accredited and obtain a surety bond by October 1, 2009 and October 2, 2009, respectively.

If you have made the decision not to obtain accreditation or a surety bond when required, you may want to voluntarily terminate your enrollment in the Medicare program before the implementation dates above. You can voluntary terminate your enrollment with the Medicare program by completing the sections associated with voluntary termination on page 4 of the Medicare enrollment application (CMS-855S). Once complete, you should sign, date and send the completed application to the National Supplier Clearinghouse (NSC). By voluntarily terminating your Medicare enrollment, you will preserve your right to re-enroll in Medicare once you meet the requirements to participate in the Medicare program.

If you do not comply with the accreditation and surety bond requirements and do not submit a voluntary termination, your Medicare billing privileges will be revoked. A revocation will bar you from re-enrolling in Medicare for at least one year after the date of revocation.

Suppliers who do not plan to stay enrolled in Medicare are strongly encouraged to notify their beneficiaries as soon as possible so the beneficiary can find another supplier.

For additional information regarding DMEPOS accreditation or the provisions associated with a surety bond, go to http://www.cms.hhs.gov/MedicareProviderSupEnroll. Frequently Asked Questions (FAQs) on the surety bond requirement can be found on the NSC?s FAQ page at http://www.palmettogba.com/nsc.

The Medicare Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) competitive bidding program Round 1 Rebid is coming soon!!

Summer 2009

• CMS announces bidding schedule/schedule of education events
• CMS begins bidder education campaign
• Bidder registration period to obtain userID and passwords begins

Fall 2009

• Bidding begins

If you are a supplier interested in bidding, prepare now - don't wait!

UPDATE YOUR NSC FILES: DMEPOS supplier standard # 2 requires ALL suppliers to notify the National Supplier Clearinghouse (NSC) of any change to the information provided on the Medicare enrollment application (CMS-855S) within 30 days of the change. DMEPOS suppliers should use the 3/09 version of the CMS-855S and should review and update:

. The list of products and services found in section 2.D;
. The Authorized Official(s) information in sections 6A and 15; and
. The correspondence address in section 2A2 of the CMS-855S.
This is especially important for suppliers who will be involved in the Medicare DMEPOS Competitive Bidding Program. These suppliers must ensure the information listed on their supplier files is accurate to enable participation in this program. Information and instructions on how to submit a change of information may be found on the NSC Web site (http://www.palmettogba.com/nsc) and by following this path: Supplier Enrollment/Change of Information/Change of Information Guide.

GET LICENSED: Suppliers submitting a bid for a product category in a competitive bidding area (CBA) must meet all DMEPOS state licensure requirements and other applicable state licensure requirements, if any, for that product category for every state in that CBA. Prior to submitting a bid for a CBA and product category, the supplier must have a copy of the applicable state licenses on file with the NSC. As part of the bid evaluation we will verify with the NSC that the supplier has on file a copy of all applicable required state license(s).

GET ACCREDITED: CMS would like to remind DMEPOS suppliers that time is running out to obtain accreditation by the September 30, 2009 deadline or risk having their Medicare Part B billing privileges revoked on October 1, 2009. Accreditation takes an average of 6 months to complete. DMEPOS suppliers should contact a CMS deemed accreditation organization to obtain information about the accreditation process and the application process. Suppliers must be accredited for a product category in order to submit a bid for that product category. CMS cannot contract with suppliers that are not accredited by a CMS-approved accreditation organization.

Further information on the DMEPOS accreditation requirements along with a list of the accreditation organizations and those professionals and other persons exempted from accreditation may be found at the CMS website: http://www.cms.hhs.gov/MedicareProviderSupEnroll/01_Overview.asp

GET BONDED: CMS would like to remind DMEPOS suppliers that certain suppliers will need to obtain and submit a surety bond by the October 2, 2009 deadline or risk having their Medicare Part B billing privileges revoked. Suppliers subject to the bonding requirement must be bonded in order to bid in the DMEPOS competitive bidding program. A list of sureties from which a bond can be secured is found at the Department of the Treasury's "List of Certified (Surety Bond) Companies;" the web site is located at: www.fms.treas.gov/c570/c570_a-z.html.

Visit the CMS website at http://www.cms.hhs.gov/DMEPOSCompetitiveBid/ for the latest information on the DMEPOS competitive bidding program

Following an announcement by the U. S. Food and Drug Administration (FDA) warning consumers of a tainted skin sanitizer, the Centers for Medicare & Medicaid Services (CMS) is advising health care providers and consumers not to use skin products made by Clarcon Biological Chemistry Laboratory.  Clarcon is voluntarily recalling some skin sanitizers and skin protectants marketed under several different brand names because of high levels of disease-causing bacteria found in the product during a recent inspection.

Consumers and providers are being warned to not use any Clarcon products and to throw these products away in household refuse.

FDA analyses of several samples of Clarcon products revealed high levels of various bacteria, including some associated with unsanitary conditions. Some of these bacteria can cause opportunistic infections of the skin and underlying tissues.  Such infections may need medical or surgical attention, and may result in permanent damage. Examples of products that should be discarded include:
            Citrushield Lotion
            Dermasentials DermaBarrier
            Dermassentials by Clarcon Antimicrobial Hand Sanitizer
            Iron Fist Barrier Hand Treatment
            Skin Shield Restaurant
            Skin Shield Industrial
            Skin Shield Beauty Salon Lotion
            Total Skin Care Beauty
            Total Skin Care Work

Health care professionals and consumers may report serious adverse events (side effects) or product quality problems with the use of this product to the FDA's MedWatch Adverse Event Reporting program either online, by regular mail, fax or phone.
--Online 
--Regular Mail: use postage-paid FDA form 3500 and mail to MedWatch, 5600 Fishers Lane, Rockville, MD 20852-9787
--Fax: 800-FDA-0178
--Phone: 800-FDA-1088

For more information:
http://www.fda.gov/ForConsumers/ConsumerUpdates/ucm164845.htm

WHEN:  The move will take place during the last week of June.

WHERE: We’re moving to the corner of 13th and K Streets, NW, Washington.  The location is directly across from Franklin Square, one block from McPherson Square Metro, four blocks from Metro Center, five minutes from Union Station and just fifteen minutes from Washington National Airport.

As of July 1, 2009 our new mailing address:

Community Health Accreditation Program
1275 K Street, NW
Suite 800
Washington, D.C. 20005

Please continue to use the current mailing address until July 1, 2009.

Phone numbers and email addresses will remain the same.
Additional information will follow shortly.

CHAP MEMORANDUM

TO:	HOME HEALTH, HOSPICE, HME AND PHARMACY ORGANIZATIONS SEEKING NEW OR CONTINUING ACCREDITATION
FROM:	TERRY A. DUNCOMBE, PRESIDENT/CEO
SUBJECT:	TIMING OF SITE VISITS AND OTHER UPDATES
DATE:	JANUARY 29, 2009
In May of last year, we posted a notice on our web site explaining what organizations could expect in terms of a timely site visit. I wanted to provide some updates and additional information. HME and Pharmacy: The September 30, 2009 deadline for CMS DMEPOS Providers with an Active Medicare Provider Number (PTAN) to become accredited in order to retain their provider number and ability to bill Medicare is quickly approaching! CMS has urged suppliers to plan to have an accreditation application in to their chosen accrediting organization by the end of January in order to meet that deadline. For Providers who do not currently have a Medicare Provider Number (PTAN), as of March 1, 2008, accreditation is required PRIOR TO submitting the 855S application for a provider number. Through our electronic application and self study process, CHAP is fully prepared to assist organizations in meeting the September 30th deadline. CHAP has not had any delay in conducting unannounced Site Visits for accreditation once the Self Studies have been submitted by organizations indicating their readiness. We are developing web based training for new organizations on how to achieve CHAP accreditation, designed to demystify and facilitate your process. We anticipate release in the next month, so please check back on our web site. Home Health and Hospice: Deprioritization of initial certification surveys by CMS for state survey and certification offices continues to direct a heavy stream of new applicants for accreditation with deemed status to CHAP. We are delighted to be of service and have taken many steps to improve our ability to provide accreditation services that add value, as well as a site visit in a timely manner. These include adding almost 20 new site visit staff, as well as many other changes in our internal systems and processes. We continue to recruit and develop our organization to support you! We are working carefully to meet the needs of our currently accredited organizations as well as our new applicants and working to ensure your organization continues to be in compliance with all state and federal requirements for Medicare certification and continuing CHAP accreditation. As always, CHAP will schedule site visits to organizations that have submitted a complete self study, and notified us of readiness, in the date order this notification is received. Here is how you can help ensure the best service from us:   1. Ensure that you use the self study tools and process to not only develop structure but also process for home health and hospice accreditation standards.   2. Ensure that you have forwarded a copy of your OASIS test transmission report (home health only) and your “855 review completed” letter from your fiscal intermediary. These documents must be on file with CHAP before we can schedule your site visit.   3. Ensure that you meet minimum census requirements and notify us. For deemed status, home health must have served 10 patients and have 7 active at the time of the site visit, and hospices must have served 5 and have 3 active patients. These are not required to be Medicare patients. We are very aware of the tremendous operational and financial challenges these CMS requirements create, in the face of an average of 6 – 8 month wait after you have submitted your self study and the documents noted above for your unannounced home health and hospice site visit We will continue to work aggressively to narrow that wait time back to our traditional standard of 1-4 months. Meanwhile, we will work together with you to the best of our ability to keep you informed, and provide support and assistance. Unfortunately, we have encountered a number of occasions in which organizations stated they were ready for site visit, but upon arrival, the required census was not in place. In these cases, we cannot complete your site visit. We will bill you for the site visit days and you will be moved to the bottom of our site visit schedule list. Please help us ensure full productivity of our site visitors. New Hospice Standards: Our Standards of Excellence for Hospice have been updated to reflect the new Conditions of Participation. These were sent to all currently accredited hospice organizations, and are being issued to all new applicants as well as those beginning a new accreditation contract. We are developing web based training on the new standards which we expect to be available in the next month. Check back for more information! Electronic application and self studies: All new applicants for accreditation are using our electronic web based tool. This tool provides clear direction about information needed, and helps establish an accurate accreditation record for you in our CARES system. Many organizations are not aware that you can also complete your self study electronically. Please contact us to set you up with training and access. All of us at CHAP appreciate the opportunity to be of service to you, and to further quality improvement in community based care. Please do not hesitate to contact us if you have questions or need additional information.