CMS has approved 10 Accreditation Organizations (AOs). Three of the AOs are prosthetic/orthotic based, one is for rehabilitation facilities, leaving the remaining six for pharmacy accreditation. The AOs listed by CMS and used by the PRS DAPP Program are as follows :

• CHAP (Community Health Accreditation Program)
• ACHC (Accreditation Commission for Health Care, Inc.)
• NABP (National Association of Boards of Pharmacy)
• The Compliance Team, Inc.
• JCAHO (Joint Commission on Accreditation of Healthcare Organizations) * available in a future update

1. Cost Associated with Accreditation
2. Length of the Accreditation Period
3. Accreditation Process
4. Interpretation of the Quality Standards

Consider the accreditation process as follows:

1. Update your CMS-855S Form – If the information on your AO application doesn’t match the information on your CMS-855S Form, you may have your application returned!

2. Submit Application – After you submit an application, when does the clock begin ticking before a Surveyor arrives unannounced at your pharmacy counter? (Check timing once AO receives application.)

3. Crosswalk Standards – You will need to compare standards of the AO with your pharmacy’s existing policies, procedures and practices.

4. Develop Operating Budget – You will need an operating budget and may need to consult with an accountant to develop one for your business. An AO will only accredit those pharmacies with a stable financial structure. (An operating budget will also be necessary if you plan on participating in Competitive Bidding.)

5. Creation & Implementation of Compliance Program – You may need to revise your existing policies, procedures, and practices to ensure compliance with the AO’s standards. If your pharmacy doesn’t have written policies and procedures, you will need to create and implement policies and procedures for compliance. This is a very time consuming endeavor.

6. Prepare for Survey – It’s not enough to have a DMEPOS Policy and Procedure Manual. You will need to ensure that compliance occurs on a day-to-day basis utilizing self-surveys to ensure that personnel are implementing the training that was conducted and in accordance with your DMEPOS Compliance Policy and Procedure Manual.

7. Survey – Surveyor spends 1-2 days at pharmacy (dependent on the extent of your DMEPOS business operation). Surveyors may (1) observe employees, (2) review policies and procedures, and practices, and (3) interview patient(s) to ascertain if the pharmacy is in compliance with the AO’s quality standards.

8. Review Findings – The Surveyor will review the findings of the Survey with the pharmacy owner and point out deficiencies with compliance. This may occur immediately following the survey or via a written review. Instructions will be provided by the Surveyor on what would be required as proof of compliance. Depending on the severity of the deficiency(s), another survey may be warranted or accreditation may not be awarded.

9. Correct Deficiencies – The pharmacy shall correct deficiencies and provide proof of compliance via submitting policies/procedures or a statement that corrections have been made, as instructed by the Surveyor.

10. PHARMACY IS ACCREDITED!

11. Continuous Compliance – Pharmacy needs to maintain continuous compliance throughout the accreditation period utilizing self-audits, maintaining required logbooks and forms, and revising policies and procedures as necessary to ensure compliance.

The process listed above is a general description of what to expect. Each AO varies on the application process and the assistance they offer during the accreditation process. An AO may have a process that is done entirely online while others offer a combination of hardcopy and electronic submittal/assistance with assistance ranging from a call center or internet based work shops to contacting an assigned surveyor. What is guaranteed is that all AOs will conduct an on-site survey for accreditation.

The cost associated with accreditation also varies and depends on the extent of your DMEPOS business and the length of the accreditation period. Some AOs have a 2 year accreditation term while others provide a 3 year accreditation term. You need to consider the cost over the length of the accreditation period. At a minimum, you can expect (1) the application fee, (2) a survey fee, and (3) a yearly accreditation fee. Additional costs include an accounting consultant for development of an operating budget and the cost of the time expenditure to develop policies and procedures in compliance with the AO’s quality standards.

You also need to consider what you will need to accomplish to meet the AO’s quality standards. CMS has provided quality standards that each of the AOs interpret and then base their accreditation quality standards on. Some of the AOs make their standards available at no charge; others are available only with your application fee. Also consider whether there are programs available for the DMEPOS business that you do such as limited DME (diabetic supplies and an occasional walker/cane) versus a full-line of DMEPOS (to include oxygen, wheelchairs, and custom orthotics).

Another consideration is the time frame from application submission to survey date. The range can go from 30-45 days to 3-4 months. This depends to some extent on the data that will be reviewed during the survey and the backlog at the AO. For example, you may not be surveyed until 4 months after you submit your application because the surveyor may want to see 4 months of documentation on Performance Management. Then again, another AO may conduct a survey within 30 days from submittal of your accreditation application. You need to be ready and know what needs to be in place for the survey. You also need to consider if there is a backlog of applications at an AO.

No matter which organization you choose, the sooner you prepare for accreditation the better. So that by the time your accreditation deadline creeps up on your pharmacy, you already have practices established that have become second nature to your employees, accumulation of data for Performance Management review, working operating budgets in place, and satisfied beneficiaries for the surveyor to interview.

CMS has now provided an accreditation deadline of end of August 31, 2007 for those pharmacies participating in the first round of Competitive Bidding program!