Home Health & Hospice Week

CMS urges suppliers to submit detailed comments on controversial standards.

Suppliers hoping draft quality standards would calm the waves of change rocking the industry may want to take a Dramamine.

The Centers for Medicare & Medicaid Services unveiled the long-awaited standards, which were drawn up by Cambridge, MA-based contractor Abt Associates, on Friday, Sept. 23 and held a special Open Door Forum to discuss them on Monday, Sept. 26. The public forum took place during the first afternoon of the two-day meeting of the Program Advisory & Oversight Committee on competitive bidding, which was held in Pikeville, MD. The PAOC also discussed the draft standards during its meeting.

Almost 500 people attended the 90-minute forum in person and by phone, raising many questions about what exactly the standards mean, how they will be implemented and how they will affect durable medical equipment suppliers. CMS and Abt representatives acknowledged they don't have all the answers--and that they're relying on suppliers' responses to refine the proposal.

"There was never any expectation that this would be totally right from the beginning," said Steven Levenson, a CMS contractor for the project and president-elect of the American Medical Directors Association. "There's great receptivity to feedback."

All Requirements May Not Be 'Doable'

The 109-page draft document includes two sections--one focusing on business standards that apply to all suppliers and another on standards for suppliers specializing in specific products. The business standards detail requirements in eight areas: administration, financial management, human resource management, beneficiary services, performance management, equipment and safety, beneficiary rights and ethics, and information management.

The product-specific section discusses service standards and requirements for inspection, delivery and setup, and beneficiary education and training for 13 product categories ranging from oxygen and related equipment to commodes, bedpans and urinals. This section remains a "work in progress" to be completed by January 2006, according to the draft document. Abt plans to develop standards for additional categories of items, Abt's Debra Frankel told the forum.

The financial-management requirement that suppliers maintain adequate resources to ensure they can meet their obligations each quarter raised concerns for Pharr, TX-based Marshall Mobility Plus. A rep asked whether the requirement means suppliers must have three months' worth of operating expenses and average accounts payable in the bank at all times.

The project officials admitted they don't know the answer. "A lot of this will need to be developed by the accreditation agencies in terms of the details," Levenson said. "That's the reason for having this feedback--there's the possibility that these may not be doable."

Service Deadlines Discussed

Oxygen suppliers also protested the requirement that they respond within 60 minutes of receiving a service call from a beneficiary or caregiver, noting that this would be difficult in regions with inclement weather.

"Let's just say this is a rather popular area for comment and concern," Levenson replied, evoking laughter from the PAOC meeting attendees. "It's certainly appropriate to get feedback on what people consider to be realistic and reasonable."

The public comment period for the draft quality standards ends Nov. 28. CMS plans to publish the final standards by April 2006. It will do so via program instructions to give the agency more flexibility on revisions.

Around the same time CMS publishes the final quality standards, it plans to announce the 10 metropolitan statistical areas where it will test competitive bidding. The quality standards will be phased in first within those 10 MSAs, and the accrediting organizations will first focus on suppliers in those areas. But there could be quality-assurance options other than accreditation still to be announced, a CMS official told the forum.

Note: A copy of the draft standards and instructions on submitting comments are at www.cms.hhs.gov/suppliers/dmepos/compbid/default.asp.