Home Health & Hospice Week

You don't have to be accredited by the Dec. 2 deadline for the hospice CoPs if you serve hospice patients, but you have to be getting there.

Suppliers and hospices panicked by the De-cember hospice Conditions of Participation deadline called into the Centers for Medicare & Medicaid Services' Open Door Forum for home care providers on Aug. 13 requesting more information, which CMS didn't give at the time.

A Dec. 2 deadline for DME accreditation is "unreasonable," said a caller from Palliative Home Care of Niagara in Niagara Falls, NY. Currently the Medicare law passed this summer requires DME accreditation only by September 2009, unless you're a new supplier applying for a supplier number for the first time.

DME and hospice providers need a quick clarification on the accreditation requirements, Bruce Rodman with the National Home Infusion Association said in the forum that drew 394 callers.

CMS responds: On Aug. 19, CMS sent a followup email clarifying the accreditation requirement in the CoPs. "If a hospice has a contract with a DME (that has a Medicare supplier number), the hospice should have a letter in their file from the DME stating the DME has applied and is waiting for accreditation by the 9/09 date," CMS instructs in the email. "If the hospice contracts with a DME that only serves hospice, (therefore no Medicare supplier number), the hospice will need to make sure the same type of letter from the DME is in place in their files."

If the hospice owns its own DME company, no accreditation is necessary, CMS adds.

Other issues raised in the forum include:

• MIPPA. Suppliers are waiting for details and clarification on multiple Medicare Improve-ments for Patients and Providers Act of 2008 issues, including accreditation for physicians, oxygen title transfers and competitive bidding. Suppliers in the forum seemed particularly interested in possible compensation suppliers might receive if they were winning bidders whose contracts were terminated.

But the agency isn't saying much yet. "CMS continues to examine the language of the statute and prepare for implementation of various provisions under MIPPA, including re-implementation of Round 1 of competitive bidding," it says in the same followup email. "With respect to the promulgation of new requirements under MIPPA, we are not yet prepared to say what form/process that will involve."

Stay tuned: "CMS (and its contractors) will provide further guidance to suppliers in the near future," the agency pledges.

• PDAC. The new Pricing, Data Analysis and Coding (PDAC) contractor for DME has taken over certain duties from Palmetto GBA's Statistical Analysis DME Regional Carrier (SADMERC). Nor-idian Administrative Services is the new PDAC and has a Web site at www.dmepdac.com, noted Nancy Saltzman with the CMS Dallas regional office.

HCPCS code verification letters have transferred to the PDAC but won't start a new 90-day timeclock, Saltzman noted. That's good for suppliers waiting on the letters. If you already have a verification letter from the old SADMERC, you don't need a new one, she added.

• GAO report. CMS is working with its general counsel on new guidance in light of the Government Accountability Office's recent report slamming its laxity with supplier enrollment procedures (see Eli's HCW, Vol. XVII, No. 28, p. 221).

Erik Sokol with the Power Mobility Coa-lition asked whether CMS might move up or reconfigure the September 2009 accreditation deadline for all suppliers. "I wish I had an answer for you today," said CMS' Sandra Bastinelli.

• CPAPs. Suppliers are alarmed by major changes to contractors' local coverage determinations for continuous positive airway pressure devices issued last month, said Walt Gorski with the American Association for Homecare. The LCDs address payment for different CPAP devices and who may conduct sleep testing. "These are significant changes and departures from the current policy," Gorski told CMS.

CPAP suppliers would like more guidance from CMS on this issue in next month's forum, Gor-ski asked in the forum.