Accreditation Corner

DMEPOS ACCREDITATION: Performance Management

By Harry Lattanzio, R.Ph.

Do you currently audit your practice to determine when additional policies, procedures, and/or training is needed? Some of you may be familiar with another type of Performance Management. In the past few years many states have put Continuous Quality Improvement regulations in place, which require the pharmacy to document all errors, and routinely meet with staff to discuss ways to prevent the errors. If a pharmacy seeks accreditation in order to submit claims to Medicare for Part B DMEPOS, a detailed Performance Management Plan needs to be instituted. To put it in the words of CMS:

"The supplier shall implement a performance management plan that measures the outcomes of consumer services, billing practices, and adverse events. The data collection may target certain aspects of services that have a potential to cause harm or injury; occur frequently, creating a greater than expected number of adjustments, repairs, or replacement; or require significant instruction to assure safe use and benefit of items."

Additionally, CMS describes some necessary outcomes, at a minimum, that the pharmacy must measure.

CMS wants the pharmacy to conduct a review of all the Beneficiary Satisfaction Surveys and complaints made about the pharmacy's services and products. The Beneficiary Satisfaction Survey is a survey given to a Medicare beneficiary after he or she receives products or services from the pharmacy. These Surveys measure criteria such as customer service, quality and ease of use of the product, and effectiveness of the training received. The Surveys also provide an opportunity for the beneficiary to add any additional comments or complaints they would like to make.

In addition to reducing costs, CMS is concerned about DMEPOS product and service availability within a given location. It is for this reason the pharmacy will have to conduct a quarterly business impact review. This review will allow the pharmacy to gauge the impact that a change in the business practices has had on the beneficiaries/caregivers that need these products and services. For instance, if the pharmacy were to remove a product line, what impact would that have on the beneficiaries/caregivers? Will this affect the beneficiaries'/caregivers' quality of care?

It will also be the pharmacy's responsibility to track the performance of the Durable Medical Equipment provided to beneficiaries. CMS will want to know if there are adverse events happening to the beneficiaries, and if so, is it caused by inadequate or malfunctioning equipment or training issues. The pharmacy will have to maintain a log, document the occurrence, and describe the measures taken. The pharmacy will then be able to determine whether a particular item should be considered a quality item or not. This process will assist CMS in keeping quality vendors and products/services in circulation for Medicare Beneficiaries.

Also, CMS is interested in the pharmacy measuring is its response to beneficiaries'/caregivers' questions, complaints and concerns. Rather straight forward, but needless to say, something that we most likely do not do as much as we should. When a question or complaint is made, how does your pharmacy handle it? What are your time frames for getting back to the beneficiaries/caregivers? How was the pharmacy personnel's response to the beneficiaries/caregivers?

In the eyes of the pharmacy, this last performance management criteria directly effects the revenue of the pharmacy, and ensures prompt payment for services and products provided. Do you currently track the coding and billing errors made by your staff? Bottom line, you need to because this is the one item that can ensure your pharmacy is getting paid quickly and efficiently (no additional work on behalf of the pharmacy). If the pharmacy is receiving Remittance Advices (RA) with payment denials, then additional work is needed to investigate the claim to ensure the claim was coded correctly. This is additional work that can be reduced by auditing the Remittance Advices (RAs) as issues arise and educating your staff to properly submit claims.

CMS believes that the pharmacy and other suppliers who develop the above Performance Management Plan will be providing quality services and products to beneficiaries in a cost-effective and safe way. This will also ensure any potential problems that do arise can be detected and rectified through new policies, procedures, and/or training.

The author, Harry A. Lattanzio, R.Ph., is president and co-founder of PRS Pharmacy Services and owns both retail and LTC pharmacies. He has given numerous seminars throughout the country on preparing a pharmacy to pass the DMEPOS Accreditation survey.,/i>