1	Comparing the Accreditation Organizations ACPE 207-000-07-143-L04P Harry A. Lattanzio, R.Ph. President PRS Pharmacy Services
2	Accreditation Organizations (AOs) American Board for Certification in Orthotics, Prosthetics, and Pedorthics (www.abcop.org) Approved for: Comprehensive orthotics & prosthetics, prefabricated custom fitted orthotics, post mastectomy prosthetics, non-custom therapeutic shoes, comprehensive therapeutic shoes, ocular prosthetics, facial prosthetics, somatic prosthetics, ancillary assistive ambulatory devices (canes, walkers, crutches) for those suppliers who qualify for O&P accreditation The National Board of Accreditation for Orthotic Suppliers (www.nbaos.org) Approved for: All orthotics - walkers, crutches, canes, dressings, hot/cold applications Commission on Accreditation of Rehabilitation Facilities (www.carf.org)
3	AO Options for Pharmacy ACHC (Accreditation Commission for Health Care) www.achc.org BOC (Board of Orthotist/Prosthetist Certification) www.bocusa.org CHAP (Community Health Accreditation Program) www.chapinc.org COMPLIANCE TEAM Exemplary Provider (C Team) www.exemplaryprovider.com HQAA (Healthcare Quality Association of Accreditation) www.hqaa.org JCAHO (Joint Commission on Accreditation of Healthcare Organizations) NOW ðThe Joint Commission www.jointcommission.org NABP (National Association of Boards of Pharmacy) www.nabp.net
4	ACHC – General Info Accreditation Commission for Health Care, Inc. www.achc.org 4700 Falls of Neuse Rd, Suite 280, Raleigh, NC 27609 Email: customerservice@achc.org 919.785.1214 voice / 919.785.3011 fax Established 1986 “1^st healthcare accrediting body in the world” to be Certified to ISO 9001:2000 Standards / May 2004 (ISO = International Organization for Standardization)
5	ACHC – The Process & Fees Request ACHC Manual (Manual = Standards) w Standards / $300 w Electronic or Printed Manual (additional $100 + shipping) Utilize Self-Assessment to determine current degree of compliance Prepare for Survey utilizing standards Submit Application and Contract for Survey with application Deposit ($1,500 Deposit is applied to Survey cost) UNANNOUNCED SURVEY w/in 3-6 MONTHS FROM SUBMITTAL OF APP BE SURVEY-READY WHEN YOU SUBMIT APPLICATION! Submit PER w/ app (Preliminary Evidence Report = P/Ps, Financials, etc.) ACHC assigns Surveyor Accreditation Fee is based on # of survey days ($3,800/day) No other fees; No annual fees!
6	ACHC – The Survey # of on-site Survey days determined by (1) # clients/patients per service, (2) # of locations to be surveyed, (3) # of employees Typical “Pharmacy” Survey = 1-2 days (additional days, if necessary, and charged for according to Survey Contract) Survey Conducted x Conduct Interviews with staff and clients x On-Site Review: personnel files, client records, budgetary information, policies and procedures, quality improvement plans, and operational and service delivery outcomes Scored at HQ – min. of 90% in each section and each scope of service evaluated þ Accredited þ Deferred (90 days to correct deficiencies / rarely means another survey) þ Denial (<5% surveyed / cellophane still on CD program) Accreditation awarded for 3 years (start 1^st day following last day of survey) ACHC may make unannounced on-site visit at any time during 3-year period and if in non-compliance, survey fees/expenses billed to you
7	ACHC – Other Info Ä Checklist to Success Preparation Guide Available for $70 + shipping Ä Group Membership Discounts on Manual & Preparation Guide Ø ABC, McKesson, Cardinal + more Ä Pre-Survey Checklists available to download in English & Spanish
8	ACHC – Provider Types Ordering the Manual (Standards) . . . EQUIPMENT/SUPPLIES Ø Medical Supply Provider: Provides medical supplies only with no rentals (specifically written/developed for Pharmacy) Providing only Diabetic Supplies – These standards are for you! Ø Home/Durable Medical Equipment: Provides DME and/or Oxygen PHARMACY For Specialty or Compounding Pharmacies THIS IS NOT FOR TYPICAL RETAIL PHARMACY Ø Pharmacy: Includes: Ambulatory Infusion Center, Respiratory Nebulizer Medication, First Dose Pharmacy, Specialty Pharmacy, Infusion Pharmacy & Infusion Nursing
9	BOC – General Info Board for Orthotist/Prothetist Certification www.bocusa.org 7150 Columbia Gateway Drive, Suite G, Columbia, Maryland 21045-1151 Hours: Mon-Fri 8:30am – 5:30pm est Email: info@bocusa.org 1.877.776.2200 phone / 410.872.9298 fax Founded 1984 (by pharmacist) Facility Accreditation for DMEPOS Providers
10	BOC – Provider Types Provides full range orthotic and/or prosthetic services Limited to fitting prefab orthotic devices, prefab therapeutic shoes, arch supports, prefab post mastectomy prostheses supplies Provides prefab HME/DME products & services Limited to fitting prefab post mastectomy products & related supplies Limited to custom & prefab shoes, arch supports & orthotic devices allowed w/in scope of licensed and/or certified pedorthic practice
11	BOC – The Process Download Application Prepare for accreditation utilizing BOC Standards contained w/in application along with the CMS 21 Quality Standards Complete Facility Accreditation for DMEPOS Providers Application and Affidavit Submit documentation as specified in app (e.g. floor plan, licenses, employee handbook, DME Compliance Manual, etc.) ª Electronic submittal available early 2008 UNANNOUNCED SURVEY CONDUCTED w/in 30-DAYS FROM SUBMITTAL OF APP BE SURVEY-READY WHEN YOU SUBMIT APPLICATION!
12	BOC – The Survey Scoring based on yes/no answers to On-Site Survey 15 or < non critical “NO”s – Correct deficiencies & submit appropriate documentation – then accredited >15 non critical “NO”s – correct deficiencies & submit appropriate documentation & another on-site survey 1 critical “NO” – correct deficiencies & submit appropriate verification w/in 30 days of notification letter & another survey >1 critical “NO” – facility failed! Reapply after 50 day waiting period.
13	BOC – The Fees For Supplier Type 1, 2, 3 and 5 w Initial app & accreditation fee per location $1,475 w Additional Initial Site Visits fee – 0 – (up to 2 locations, and/or <50 miles from original facility) w Additional Initial Site Visits fee $750 (>2 locations and/or >50 miles from original facility) w Secondary (return) Site Visit if necessary $750 w 2^nd Year Annual Renewal Fee $575 w 3^rd Year Annual Renewal Fee $575 (Fees are subject to change)
14	BOC – Other Info ü BOC offers sources for: DMEPOS Policy & Procedure Manuals DMEPOS Consulting Services ü BOC accredits only the DMEPOS portion of your pharmacy business ü Their Advice: Begin Preparing Now! For the next round . . . 70 MSA’s to be announced by CMS / late 2007-early 2008?
15	CHAP – General Info Community Health Accreditation Program www.chapinc.org HQ: 1300 19^th Street, NW, Suite 150, Washington, DC 20036 Phone: 800.656.9656 Fax: 202.862.3419 info@chapinc.org Established 1965; 2001 spun-off by the NLN and became an independent, non-profit corporation (NLN = National League for Nursing)
16	CHAP – Suppliers & Fees CHAP accredits SEPARATE & DISTINCT Programs/Services individually to include: ð HME(DME) and if you choose ð Pharmacy Standards ð Core (Trunk of Tree) and (Branches) ðHME ðPharmacy FEES: (All fees non-refundable.) ¥ App fee $500 ¥ Accreditation fee divided by 3 annual payments ¥ Separate per diem charge of $995 per site visit day Site Visit days & Accreditation Fees based on: ¤ size & complexity of organization ¤ # of different services provided ¤ # of locations & distance from parent ¤ gross revenues ¤ unduplicated census (admissions, hrs, service units, visits, mailing, initial set-ups, & deliveries) of each location for last fiscal year TO OBTAIN AN ESTIMATE ð email above info to info@chapinc.org DISCOUNTS available to some State Associations
17	CHAP – The Process Step 1. APPLICATION submittal w/ fee CHAP: (a) reviews eligibility (b) estimates # site visit days (c) sends contract to applicant Once contract signed & returned Ä Standards & Self Studies sent to applicant (Not under contract, may purchase @ $200 set) Step 2. SELF STUDIES Self-evaluation tool / DUE 3-6 months CHAP: (a) review documents for completeness (b) analysis of content (used to plan & execute site visit)
18	CHAP – The Process (con’t) Step 3. SITE VISIT - designed to be a positive learning experience w/ ü Site Visitors acting as consultants to help your organization prosper & grow ü Site Visitors specifically matched to your organization TYPES þ Initial Site Visit includes completion of Self Studies (FULL VISIT) Consists of: ü Entrance Conference ü Orientation to Facility / Interviews w/ Staff / Observations ü Client Visits ü Telephone Surveys ü Exit Conference ü Pre-Billing Report of CHAP Site Visit ü Consultation § Annual Site Visit § 1^st Year of a new cycle includes Self Studies (FULL VISIT) § Year 2 of a 3 Year Cycle (if necessary) § Year 3 of a 3 Year Cycle (if necessary) § Focus Visit (based on cited Required Actions) § Complaint Investigation Visit
19	CHAP – The Process (con’t) Step 4. BOARD OF REVIEW SITE VISIT REPORT = legal document that states organization’s level of compliance w/ CHAP standards REVIEWED BY BOARD - Site Visit Report & all substantiating data & docs w/ FOCUS on Required Actions cited & site visit team recommendation BOARD DETERMINATIONS: þ Accreditation þ Accreditation with Required Actions þ Accreditation with Required Actions and a Progress Report Due þ Accreditation with Required Actions, a Progress Report due, and a follow-up Focus Visit þ Defer Accreditation (initial accreditation only) (another Site Visit) þ Formal Warning (continued accreditation only) þ Deny Accreditation (initial accreditation only) þ Withdrawal of Accreditation (continued accreditation only)
20	CHAP – Their Advice Encourage you to: Ä Begin drafting P/Ps (You may already be doing the practice but needs to be written down.) Ä Work on training and proof of competency of staff Ä Read the standards before jumping into the self studies Ä Work on Performance Improvement
21	C Team – General Info The Compliance Team, Inc. / Exemplary Provider^TM www.exemplaryprovider.com PO Box 160, 905 Sheble Lane, Suite 102, Spring House, PA 19477 Email: info@ExemplaryProvider.com 215.654.9110 voice / 215.654.9068 fax The Compliance Team, Inc. Established 1994 DMEPOS Program Launched 1998 Great Seal of Asclepius
22	C Team – The Program & Standards PROVIDER TYPES: For all type of DMEPOS providers to include Pharmacy and Homecare (incorrectly listed “Approved for Categories” by CMS) FREE pdf Download of Standards & Evidence of Compliance (all docs in Microsoft Word) Offers a 2-Year Accreditation Program with annual renewal following initial enrollment period Submission of Patient Outcomes data required after initial survey (e.g. satisfaction surveys, goals/outcomes, plan of care) C Team aggregates/analyzes the data & issues quarterly Outcomes Reports (ID product or customer service issues to be addressed)
23	C Team – The Process 1^st Time applicants enroll for 2 years + orientation period (2-3 / 3-4 months) Receive Preparation CD = Standards, Self-Assessment Checklists, and Sample P/Ps, forms, logs, and plans (DME only) Receive Corporate Compliance P/Ps, forms, and plans (All Programs) Assigned Accreditation Advisor ð Supporting Documentation Review ð Series of Orientation teleconferences – focus on program requirements ð Advisor available via phone / email NEED 3 Months documentation of compliance Unannounced On-site Evaluation conducted – Score 90% or better to be accredited On-site 1-Day Evaluations are performed ANNUALLY after initial survey Quarterly Outcomes Reports & Corrective Action Plans (60-day Follow-up)
24	C Team – The Fees Boutique Pharmacy DMEPOS No O² & No Rentals; 1 Location Only Initial 2-year sign-up period - $3,900 + Travel Exp Annual Renewal Fee - $1,495 + Travel Exp Mail Order Supplies/Boutique DMEPOS No O² & No Rentals; 1 Location Only Initial 2-year sign-up period - $4,500 + Travel Exp Annual Renewal Fee - $1,495 + Travel Exp Full Service DMEPOS provider or Full Service Pharmacy DMEPOS Includes O² & Rental; 1 Location Initial 2-year sign up period - $6,900 + Travel Exp Annual Renewal Fee - $1,995 + Travel Exp Network Discounts Available è McKesson, ABC, Buying Groups Additional fees apply if more than 1 location and/or service e.g. 2 DME sites or 2 or more services (DMEPOS & Home Health Agency at 1 location) Travel Expenses are billed following completion of service Fees paid are non-refundable
25	C Team – Other Info ü “Measured Continuous Quality Improvement Program” ª Annual Evaluations ª Outcomes data submission / Quarterly Outcomes Report ª Templates: P/Ps, Forms, Logs, Job Descriptions ü Their Advice: Sign up with someone (AO) NOW! Don’t delay! ü 7 Regions throughout the US (& Puerto Rico) w/ Regional Advisors (Save on Travel Expenses) ü Electronic document submission available early 2008
26	HQAA – General Info Healthcare Quality Association on Accreditation^® www.hqaa.org 217 West 4^th Street, Waterloo, IA 50701 PO Box 1948, Waterloo, IA 50704 Phone: 866.909.4722 Fax: 877.226.5564 HQAA was created/designed specifically for DME providers
27	HQAA – Features & Fees Accreditation Approach = document review & site survey completion Paperless process Interactive using web-based design (Workroom) User Friendly Accreditation Coaches to assist throughout doc review process (3-6 months) HME portion of pharmacy business is accredited “Quick Calc” tool on website estimates your cost w $200 app fee w $100-150 month for workroom & coach w Survey fee based on annual sales w Provider pays for Surveyor’s travel/lodging
28	HQAA – The Application Complete Demographics section Complete Payment System application for “My Workroom” fees = personalized tracking & maintenance system for getting through the standards Choose to submit app to finance the process (HQAA does not provide financing) Issued Temporary Password & partial access Participate in Tutorial (make the most of workroom) After Confirmation of Payment – receive notice to personalize your password & you are on your way! Begin with “The Focus Assessment” = management tool to assist you in being objective about where you rate your organization – discuss & identify areas to be improved
29	HQAA – Document Review Workroom - Modules of HQAA Standards assigned Coach - receive, review, & assist w/ docs as created or existing è Each standard has own workroom web page and contains: Standards – guidance as to processes required (best practices) Evidence of Compliance – offers items, areas, policies that demonstrate compliance ex) Evidence for cleaning & maintaining equipment is a Cleaning & Maintenance Policy w/ Cleaning Log Examples to Validate – Provides suggestions on how the standard may be observed or what a surveyor may look for during a site visit 100% completion of online requirement ðSurveyor Assigned
30	HQAA – The Survey SURVEYOR: Reviews docs submitted to Workroom Conducts telephone interview THE SURVEY (unannounced) ª Opening Conference ª Tour of Facility – Staff Interviews – Equipment Review ª Client Visits (determined during telephone interview w/ surveyor) ª Telephone Surveys (if necessary) ª Exit Conference (address findings, discuss strengths, deficiencies, & recommendations to Accreditation Review Committee, opportunity to ask questions or seek clarification)
31	HQAA – Award or Deny Accreditation AWARDED Complies or partially complies w/ majority of standards Partial Compliance / Deficiencies ð corrected to full compliance Proven via focused onsite survey (w/in 2-6 months of previous survey) and/or submission of Post-survey Outcomes Report and approval of Post-survey Progress Report FAIL focused survey ð Accreditation Denied Accreditation DENIED Ø Corrective actions too numerous – standards not achievable Ø Operational practices compromise patient or employee safety Ø Wait 1-Year before re-applying w/ HQAA Ø Can appeal decision
32	JCAHO – General Info The Joint Commission (formerly JCAHO – Joint Commission on Accreditation of Healthcare Organizations) www.jointcommission.org HQ & Conference Center: The Joint Commission, One Renaissance Blvd, Oakbrook Terrace, IL 60181 General Phone: 630.792.5000 Fax: 630.792.5005 Customer Service: 630.792.5800 customerservice@jointcommission.org Established 1951 1^st accreditor of DME organization . . . since 1988
33	JCAHO – Getting Started Request free “readiness” toolkit: DMEPOS Checklist DMEPOS Accreditation Guide (how to get started, what to expect, informative Q/As) 2007 Pricing Worksheet 2007 Accreditation Requirements Guide Contact Information Very Informative Overview!
34	JCAHO – The Standards Standards continually reviewed Updates provided to accredited organizations 2x year Latest Version of ð DME standards published in: 2006-2007 Comprehensive Accreditation Manual for Home Care (CAMHC) Other additional products/services eligible for survey: ð Orthotics & Prosthetics ð Supplies – diabetic, wound care, negative pressure wound therapy, enteral nutrition, ostomy care & incontinence, hemodialysis, parenteral nutrition disposable items ð Clinical Respiratory Services ð Rehab Technology
35	JCAHO – The Process Contact Home Care Accreditation Program Staff & request application for survey ð 630.792.5771 or www.hmeaccreditation.org Letter sent to CEO w/ login, password & instructions for submitting on-line app (paper available upon request) Submit App (valid for 6 months) with Initial Deposit of $1,700 Submit App at least 4-6 months prior to requested dates (and blackout dates) of survey! Surveys are Unannounced! Receive CAMHC (manual) after submittal of app or purchase prior to submittal (www.jcrinc.com) Prepare to meet the intent of the requirements w/ 4 month “track record”. Develop new policies/procedures/processes & training. Standards Interpretation Group (SIG) available to answer your questions; interpretation of standards or whether your organization meets intent. 6) Conduct Mock Survey(s)
36	JCAHO – The Survey Notified of Survey by Classification of Organization Very Small – receive call from Account Rep 5 days prior to survey & posted to extranet site Small, Medium, Large – survey information posted to your extranet site THE MORNING OF SURVEY. Fail to accept survey w/in 6 months of app submittal ð forfeit survey deposit & must reapply Surveyors: DME professionals, owned/managed DME co. 3-5 yrs or = experience. Experience w/ your type of equip/svcs. Provide clinical respiratory services = RRT Surveyor
37	JCAHO – The Survey (cont’d) ü Priority Focus Areas (PFA) and Clinical Service Groups (CSG) - posted to extranet site ü Patient Tracers & System Tracers KEY ACTIVITIES 1) Orientation to Organization 5) Education 2) Staff Interviews 6) Daily Briefing 3) Home visits 7) CEO exit Briefing 4) Review of entire environment of care (warehouse, delivery vehicle, patient homes, offices, etc.) Average Survey = 2 days / some 1 day; others 5
38	JCAHO – Scoring, EP, ESC, & MOS Surveyors Evaluate compliance w/ each standard by evaluating each component of the standard or Elements of Performance (EP) Score EPs utilizing 3-point Scale 2 = Full Compliance 1 = Partial Compliance 0 = Non-Compliant Initial Survey – standards met for a period of at least 4 months prior to date of survey Requirement for Improvement – have 45 days after receipt of Surveyor Report to demonstrate compliance (Evidence of Standards Compliance – ESC) For some EPs Not in Satisfactory Compliance – submit ESC w/ Measures of Success (MOS) – method of measurement to validate effective & sustained compliance for EP – completion of MOS due 6 months following ESC & MOS acceptance
39	JCAHO – Categories of Accreditation þ Accredited – Gold Seal of Approval^TMawarded for 3 years þ Provisional Accreditation þ Conditional Accreditation þ Preliminary Denial of Accreditation þ Denial of Accreditation þ Preliminary Accreditation (Early Survey Option)
40	JCAHO – The Fees w # of Patients served = Average Daily Census (ADC) ADC On-Site Fee 1-50 $1,270 51-300 $1,900 301-999 $2,520 1000+ $3,580 w # of Offices/Sites & Distance from Main Site On-Site Fee Miles from Main Site Per Additional Location 1-59 $400 60-119 $745 120-199 $1,095 200+ $1,410 w Annual Fee ADC Annual Fee 1-50 $785 x 3 (Accreditation Cycle) 51-300 $1,140 x 3 (Accreditation Cycle) 301-999 $1,555 x 3 (Accreditation Cycle) 1000+ $2,210 x 3 (Accreditation Cycle)
41	JCAHO – Other Info ü Attend a Joint Commission-sponsored seminar about the standards, survey process and/or performance improvement concepts. ü Request Home Care Bulletin – complimentary newsletter ü Once Accredited – receive monthly newsletter Perspectives (official correspondence of any policy changes or new standards) ü Publishes numerous books & resources to assist in meeting standards ü Accreditation for entire organization, not individual services! (e.g. home medical equipment & pharmaceutical services) ü Services provided to patients by an outside organization on your behalf (contracted services) are also surveyed for compliance. THEIR NONcompliance is part of YOUR report and accreditation decision! ü Unannounced surveys on a random sample of 5% of accredited home care organizations from 9^th – 13^th month of accreditation period. (Continue through 2008 and then reviewed for relevance.)
42	NABP – General Info National Association of Boards of Pharmacy www.nabp.net 1600 Feehanville Drive, Mount Prospect, IL 60056 Phone: 847.391.4406 Fax: 847.391.4502 Customer Service: custserv@nabp.net 100+ years of regulatory & accreditation experience in pharmacy Utilizes CMS Quality Standards (14 pages)
43	NABP – Product Categories NABP is approved to accredit suppliers of the following DMEPOS products: Diabetic equipment and supplies Enteral and parenteral nutrients, equipment, and supplies Off-the-shelf, non-custom products and supplies Orthotics Mobility aids Wound care supplies Urological aids Medical supplies Respiratory aids For pharmacies that carry products or provide services in addition to those Listed above, NABP will coordinate with other accreditation agencies to complete the accreditation process.
44	NABP – 3 Steps to Accreditation Verification of Licensure Collects documentation demonstrating that the pharmacy is licensed and in good standing with the applicable board(s) of pharmacy or state regulatory agency. Verifies pharmacy and appropriate staff licenses. Thoroughly screens the applicant through the NABP Disciplinary Clearinghouse. Confirmation of Professional Policies and Procedures Assesses the pharmacy’s policies and procedures against CMS quality standards. Assesses the pharmacy’s compliance with CMS requirements for personnel, the pharmacy, record keeping, and patient services. On-Site Survey of the Pharmacy Experienced surveyors evaluate operations, inspect the pharmacy, interview staff, and verify documents. Compares the pharmacy’s written policies and procedures with its actual practices. CMS requires that surveys are unannounced.
45	NABP – Other Info ª NABP GOAL: complete process w/in 60 days from verified submission of all required documentation. ª Accreditation valid for 3 years ª During 3-Year Accreditation / Monitor Annually via: w Pharmacy/pharmacist disciplinary screenings through national Clearinghouse Database w Self-assessment instruments w Requiring suppliers to conduct evaluation surveys of beneficiaries (forwarded directly to NABP) w May conduct unannounced surveys (if suspected of non-compliance or in violation of state/federal laws) ª On-line Application w/ e-submittal of documents (hardcopy available upon request)
46	NABP – The Fees Fee Schedules created specifically for chain & independent pharmacies Single Pharmacy (small supplier) Application Submittal Fee (2007) $345 NABP Survey Fee $1,500 Annual Accreditation Participation Fee (2008) $150 Annual Accreditation Participation Fee (2009) $150 Total 3-Year Cost $2,145 Chains: Contact NABP for Pricing
47	NABP – Need Info? Download Information Kit (Fact Sheets) DMEPOS Accreditation Program Overview Benefits of DMEPOS Accreditation Program DMEPOS Products Approved for Accreditation by NABP DMEPOS Accreditation Program Fees FAQ Section on website – Very Informative!
48	NABP – Other Info If not participating in Competitive Bidding during 1^st Round (or 1^st 10 MSAs) then: NABP Resuming Accreditation Process January 1, 2008 Must accredit those in 1^st Round then others NABP accepting applications but processing begins Jan. Information about their DMEPOS Accreditation Program found on their website. If you have additional questions, email custserv@nabp.net