Home Health & Hospice Week

The October accreditation deadline for durable medical equipment is on top of suppliers' priority lists, with good reason -- it could sink your company if you don't comply.

If a supplier isn't accredited by Oct. 1, it will face revocation of its Medicare billing privileges, warned the Centers for Medicare & Medicaid Services in the June 30 Open Door Forum for home care providers.

And an important part of accreditation will be ensuring that your subcontractors are also accredited, noted CMS's Sandra Bastinelli in the call. The supplier standards allow for only a few narrow exceptions to that accreditation requirement.

For example: Subcontractors who furnish delivery and instruction on your equipment must be accredited, Bastinelli noted. But subcontractors who just drop-ship products with no instruction -- like FedEx -- don't need accreditation.

Real-life scenario:Many suppliers called in to the forum with questions about accreditation for subcontractors, including an enteral nutrition provider from Texas. The ENT supplier buys nutritional products from a distributor, who drops off the products at the nursing home. The ENT supplier does all the instruction for the products.

The question of accreditation hinges on the instruction element, Bastinelli illustrated. "That person does not meet the definition of the supplier," so they don't need accreditation, she explained.

Another scenario: But a mail-order diabetic supplies company that has beneficiaries pick up supplies at a local supplier will need to have that local supplier be accredited under the new rules, Bastinelli told a North Carolina caller. That's because the local supplier will provide the instruction.

As part of the accreditation push, suppliers must update their locations on the CMS-855S enrollment form, CMS's Barry Bromberg said. Locations on the accreditation forms and Medicare's enrollment forms must match.

Updating locations "is going to be crucial for billing purposes," Bastinelli stressed.

Remember: Only one DME supplier can be at each location, she added.

Suppliers that don't want to obtain accreditation and choose to give up Medicare billing privileges should voluntarily resign with the 855S form, Bastinelli advised. "Voluntarily terminating ... will reserve your right to re-enenroll," she explained.

Otherwise you'll be subject to at least a year-long ban from Medicare after the date of revocation.

Other issues raised in the forum include:

• Bidding. CMS is ready to throw its Round One rebid into high gear. Update your state licenses, update your National Supplier Clearinghouse file, and get your accreditation status squared away to prepare for the competitive bidding process that will start this fall, CMS's Joel Kaiser advised in the forum.

Obtaining licenses will be especially important for suppliers that are entering new areas or product categories, Kaiser noted.

If you don't start preparing now, you may miss out on your chance to bid, Kaiser warned. "Do what you need to do to get yourself in position to be eligible," he urged.

CMS will issue a more detailed bidding timeline later this summer, Kaiser said. Education events on the overall program, bidder registration, and how to bid will follow.

• Surety bonds. If you have questions about the DME surety bond requirement that takes effect in October, you may want to check out the surety bond frequently asked questions at www.palmettogba.com/nsc -- scroll down to the "Self Service Tools And Top Links" box, click on "Frequently Asked Questions," then click on the plus-sign next to "Surety Bond Requirements." The link to "Surety Bond FAQs" will appear.

The FAQs are "the central repository for all surety bond issues," said CMS's Frank Whelan in the call. There are currently 47 FAQs and CMS plans to add more soon, he said.

Rumor quashed: Suppliers must have a $50,000 bond for each location, Whelan reiterated.

The rumor that a chain can cap its bond at $1 million is just that -- a rumor. "There is no truth to this rumor," Whelan stressed. A chain with 100 locations must obtain $5 million of coverage.

In the FAQs, CMS estimates that a $50,000 bond will cost a typical supplier about $1,500. That means $5 million in coverage would carry a $150,000 price tag under that estimate.