I posted an email a few months ago about the accreditation standards and deadlines, which appears to be like hitting a moving target these days.
I received an email toady from CMS about the deadlines and accreditation information, and it is still unclear what is going on.
In the CMS posting, it clearly states that there are exempt people from having to get this accreditation, and it lists orthotists and prosthetists as being exempt, along with physicians, nurses, PTs, OTs, etc. I asked on this listserve if anyone had any clarification or understanding of this policy, like anyone that is sitting on any of the boards of our associations, that are supposedly working on these issues, and are there to help us out.
I never heards anything back from anyone.
Today, I got another email from CMS, again stressing the deadline for accreditation, and I went to their website to see the PDF copy of the policy. There are some interesting issues in that, which don’t make much sense to me.
Here’s a link to the PDF that they attached to their email:
http://www.cms.hhs.gov/MedicareProviderSupEnroll/Downloads/DMEPOSAccreditati
onStandards.pdf
Please read down to the part on page 16 (number 5) where it gives
defininitions. When it talks about prosthetics, it states that it is
inteneded for prosthetics for internal use, for damamged internal body
organs. Here’s the exact definition by CMS:
5. Prosthetic Devices: Devices (other than dental) which replace all or part
of an internal body organ (including contiguous tissue), or replace all or
part of the function of a permanently inoperative or malfunctioning internal
body organ. This does not require a determination that there is no
possibility that the patient’s condition may improve sometime in the future.
If the medical record, including the judgment of the attending physician,
indicates the condition is of long and indefinite duration, the test of
permanence is considered met. (Refer to Section 120 of Chapter 15 of the
Medicare Benefit Policy Manual)
I cannot see it anywhere written where this is for external prosthetics,
that replace a missing limb. It does mention somatic prosthetics, but
defines them as for fingers, hands, toes, that are damamges or missing from
trauma or congenital defects.
But, am I missing it here somewhere?
Does anyone have any clarification on these standards, and what the REAL
impact is here? Do we need accreditation or not? I know what ABC’s answer
is to this, they have been pushing for this for years….which makes a nice
impact on them financially. I know that there are many of us that just
don’t know what the answers are here, and it extremely difficult to find out
these answers. The information coming from CMS is muttled, to say the
least, and confusing. But, according to the exemptions that are listed, it
protects many of us from having to get accredited.
On a totally functional, or practical notion, for small practices, with one
or 2 practitioners (or even more possibly), when the practitioners are
already certified with ABC (or BOC), it seems to me that these practitioners
are already being held to a pretty high standard with published disciplinary
actions and procedures for anyone that commits fraud or does any illegal or
unethical practices. (See ABC’s book of rules and procedures on their
website if you don’t have your copy handy). When the individual
practitioners are already bound under this kind of agreement or rules of the
credentialling body, then why would some practitioner ALSO have to be
accredited and be under MORE rules (the same rules basically, just under a
different name) from the SAME credentialling body that only have the same
kinds of rules and guidelines?
But, back to this question that I have, from what I have read on this CMS
publication, as long as I am not making or providing internal prosthetics or
any kind of orthotics, then I guess under this publication, I am not
required to get accreditation.
Thanks
Jim DeWees, CP
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