Keep in mind that standards have changed a bit and new or additional surveyor focus and priorities certainly play a part in why these issues are problematic. Examples of standards that have changed include HR 2, the standard that talks about competency assessment. The requirement used to be “annual” but is now “every two years”. A retail store standard formerly required pricing on all items. That is no longer enforced. Other standards such as the BC (Billing/Collections) standards haven’t changed in terms of verbiage, but billing requirements have been adjusted and may be perceived to be more complex and difficult to comply with because of the changes.
It’s useful to review the frequently cited standards so all companies can make these standards a priority. I looked back at three- or four-years’ worth of survey reports for myself and several colleagues. These were the most troublesome, the most frequently cited, and the apparently, the most difficult to comply with in daily operations:
ORG 2—The standard requires you to comply with “all law and regulation”. This includes the alphabet soup of government agencies that enforce standards and have regulatory authority in our industry. FDA, OSHA, State Board of Pharmacy Licenses, State HME Licenses, and even payer sources like State Medicaid and CMS all have expectations for us. Because it’s a “catch all” standard with a lot of different requirements, it is cited often.
HR 2—This standard deals with the requirement for competency assessment. Competency assessment is simply making sure your staff providing direct and hands on care can do their jobs –well, in a word: competently. The requirement is specific to staff that has direct patient care responsibilities: delivery and any clinical staff, for instance. The requirement is that you assess their abilities to do their job by observing them doing their job. A point that some companies get hung up on is that the person doing the observation and assessment must hold similar qualifications. Thus, a clinician should have their abilities assessed by someone who is also a clinician. This requirement also applies to contracted staff.
ICS 2—Another “catch all” standard, ICS 2 lays out required safety procedures and items that must be kept on hand. Fire extinguishers, posted exit strategies, exit signage, first aid kits, and eyewash stations are all required and lack thereof are scored here.
BC 3—This standard speaks to complying with payer requirements and legal/sound/efficient/compliant insurance, Medicaid, and Medicare billing. Billing requirements have changed over the last ten years. Competitive bidding, face to face requirements, additional “written order prior to delivery” (WOPD) requirements, and newly added codes particularly in the orthotic business have all been added, enhanced, or changed. These new and more rigorous requirements have a learning curve and we see this learning curve on surveys with some regularity.
PS 2—Companies generally do a very good job obtaining physician orders. This standard is cited when those orders are missing and also when the orders are incomplete, unsigned, and/or expired. Keep in mind that many states have requirements for annual order updates.
MM 1, 2—These standards, in the Materials Management section, deal with the warehouse. Equipment should be stored safely and with considerations to any manufacturer’s recommendations. For instance, if the manufacturer says it should be stored in a given temperature range, you should be able to monitor and maintain the temperature in that section. All equipment should be up off the floor if it is still boxed because of the possibility of mildew building up under a box on a concrete floor. The most common reason for a deficiency here is the co-mingling of clean and dirty equipment. All equipment should be stored in the appropriate area. Dirty equipment should be kept together in an area with clear demarcations from the rest of the warehouse. This is to prevent accidently using contaminated, used equipment for a new patient.
DEL 2—Surveyors prefer to do “ride alongs” during survey to observe care and service. Deliveries are often the way this care and service is evaluated. The ride along puts the surveyor in the passenger seat figuratively and literally. They watch to ensure proper loading and transport, proper set up instruction, infection control with dirty equipment and handwashing before and after the home visit, and of course the paperwork associated with the delivery and care. There’s a lot to watch and evaluate and a lot that can go wrong if the employee isn’t carefully following protocols.
These standards comprise the most frequently cited standards. They aren’t the entirety of what HQAA will look for during a survey, but they are an excellent start on the road to compliance. Armed with this information, DME organizations should prepare for survey by checking themselves. Are you carefully and thoughtfully complying with the standards listed above? Do your employees know about the standards and requirements? Many of the above standards have HQAA Power Packs, which are extremely useful in maintaining compliance. Use the resources available and make sure the staff is especially aware of these areas of potential deficiency.