CMS Announces September 30, 2009, Accreditation Deadline for Current DMEPOS Suppliers
The Centers for Medicare & Medicaid Services (CMS) held a Special Open Door Forum (ODF) on December 19, 2007, to inform Medicare suppliers of durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) of the deadline for accreditation.
- The deadline by which all existing DMEPOS suppliers will need to be accredited is September 30, 2009. Suppliers that are not accredited by that point will not be able to bill Medicare for DMEPOS items.
- The deadline by which new suppliers must apply to the National Supplier Clearinghouse (NSC) for a supplier number in order to qualify for a special accreditation grace period was not announced in the ODF but will be provided to suppliers through a CMS Transmittal and MedLearn Matters educational article.
How the Announcement Affects Occupational Therapists
The Medicare Accreditation rule, released in the Federal Register on August 2, 2006, required that occupational therapists, physicians, physical therapists, and others who supply DMEPOS would have to be accredited by a CMS-approved accreditation organization in order to bill Medicare Part B for DMEPOS. This means that in order to bill either custom-fabricated or pre-fabricated orthotics (using the Level II HCPCS codes or “L” codes) to Medicare, OTs must have a separate accreditation as a “supplier.” This rule does not affect an OT’s ability to provide treatment such as orthotics management, and to bill using the CPT codes.
Note that accreditation is different from the DMEPOS competitive bidding program under Medicare. Due to AOTA advocacy, occupational therapists in private practice who bill Medicare for items of DMEPOS are exempt from bidding for those items under the competitive bidding program.
CMS continues to state that they want to minimize the burden for suppliers that have already been accredited, Medicare-certified, and/or licensed under state law. Accordingly, CMS will direct accreditation organizations to consider during the survey process any previous accreditation, certification, and/or licensure that is relevant to meeting the DMEPOS quality standards.
Each of the following organizations has received authority to accredit DMEPOS suppliers seeking to participate in the Medicare program:
- Joint Commission on Accreditation of Healthcare Organizations
- Community Health Accreditation Program
- Healthcare Quality Association on Accreditation
- National Board of Accreditation for Orthotic Suppliers (an organization of the American Society of Hand Therapists in coordination with the Hand Therapy Certification Commission)
- Board of Certification in Pedorthics
- Accreditation Commission for Healthcare, Inc.
- Board for Orthotist/Prosthetist Certification
- National Association of Boards of Pharmacy
- Commission on Accreditation of Rehabilitation Facilities
- American Board for Certification in Orthotics and Prosthetics, Inc.
CMS has information on DMEPOS supplier accreditation facts.
AOTA also has published a number of articles on DMEPOS accreditation: