A home health care agency must complete a Medicare accreditation survey in order to become Medicare certified. Medicare accreditation is required to ensure that the agency meets all of Medicare’s conditions of participation in operations and clinical patient care procedures. The first thing that a home health care agency must understand is that Medicare accreditation is a process that entails a complete review of the health care agencies organization and agency operations. The home health care agency must demonstrate the ability to meet predetermined criteria and standards of accreditation established by a professional accrediting agency. The goal of accreditation is to ensure that the agency is credible, reputable and is dedicated to ongoing and continuous compliance with the highest standard of quality. Medicare accreditation surveys are performed at the agency and last for a minimum of three days. A comprehensive review is conducted of organizational structure, compliance with federal/state/local laws, fiscal operations, policies & procedures, leadership, patients’ rights & responsibilities, provision of care, patient records, quality outcomes, performance improvement, infection control, human resource management, and patient/employee safety. Accreditation organizations employ industry experts who will conduct these surveys ensuring that the agency’s business operations and patient care provides the highest level of quality care and this is maintained throughout all aspects of the organization. Home health care agencies are required to be recertified every three years. At that time a similar process and survey will take place for a minimum of three days to ensure that home health care agency can demonstrate that they have maintained continuous compliance with the standards required by the accrediting body.
There are three organizations that have been approved by the federal government and CMS to preform Medicare surveys for accreditation. They are as follows:
- CHAP – The Community Health Accreditation Program
- ACHC – The Accreditation Commission for Health Care
- JCAHO – The Joint Commission
Below are the seven most important steps for an agency to accomplish for Medicare accreditation.
There is a mandatory capitalization requirement for home health care agencies in order to be considered eligible for Medicare accreditation. This amount money will vary according to the geographic location of the agency. These funds will need to be in the agency bank account upon submitting the Medicare 855a application, and must remain there until up to 3 months after the agency receives their Medicare billing number.
The second step for a Home Health Care agency to be Medicare certified is to register with one of the accreditation organizations. The fees for the three day surveys range from $5000.00 and up, depending on which accreditation organization is chosen.
The Accreditation Organization will require certain criteria be met in order to be considered eligible for the Medicare Accreditation Survey. The following are the four requirements;
- CMS Medicare application 855A has been accepted by one of three state specific subsidiaries of CMS. They are Palmetto GBA, NGS and CGS
- A test oasis transmittal has been successfully completed
- An online agency self-study or preliminary evidence report has been completed.
- The agency has ten skilled care patients
- A Medicare accreditation survey is unannounced and typically will take place within forty five days of readiness.
The agency must maintain 7 active patients out the 10 that are required in order to submit site visit readiness. The ten patients must all have skilled nursing services involved with the care of the patient, one must have 2 skills (Nursing/PT/OT/HHA). Patient care must be performed in the patient’s home. All patients must have a doctor’s order for skilled nursing and face to face documentation must have been completed. Patients are not require to have homebound status for the initial Medicare accreditation survey. All patients are to be treated as if they are Medicare eligible. This requires the completion of required Medicare documentation for this survey (oasis documentation, face to face documentation, all of the documentation required within the 60 Medicare certification period). Out of the ten patients, the agency is allowed to have up to three discharged patients. One of the ten patients must have a second discipline involved in the patient care. This could be one of the following:
- Home Health Aide
- Physical Therapy
- Occupational Therapy
- Speech Therapy
- Medical Social Worker
When the Medicare survey has been completed, the agency will be informed of the findings within a few weeks. There are several possibilities that may occur. They are listed below.
- Agency has passed with no deficiencies (no further action required)
- Agency has passed but has MINOR deficiencies (and action plan must be written and accepted by the accrediting body)
- Agency has condition level deficiencies (these are considered major deficiencies and will require a focus revisit by the accrediting body to determine if all deficiencies have be resolved)
- Agency has failed the survey (this will require the agency to repeat the process)
Once the agency has officially passed its Medicare accreditation survey and all plans of correction are accepted, the survey results and plan of correction (if there were deficiencies) will be looked over by the Board of Review. This review typically occurs within 30 days from the date of the survey, or from the date the plan of correction was accepted in the event there were deficiencies at the time of survey. Pending the approval of the Board of Review, the agency will be issued an accreditation letter. A copy of your accreditation letter will also forward a copy of this letter to your CMS Regional office and the state department of health. If there were no deficiencies at the time of survey, the accreditation date will be from the last day of the survey. In the event there are deficiencies, the accreditation date will begin the day the plan of correction is accepted. From the date of accreditation, any Medicare patients that the agency services can be eligible for payment reimbursement when the agency receives its billing number. Now that the state has received notification of your successful accreditation, the state will confirm that the agency still meets their requirements to be Medicare eligible. We suggest that the agency call their state contact one week after you receive the accrediting organizations letter. CMS will then contact agency’s fiscal intermediary and ask them to recheck all paper work. The fiscal intermediary will then email the agency a request for re-verification of the required capitalization. If the agency does not hear from the Fiscal Intermediary (Palmetto, NGS, or CGS) within three weeks, they should call the person who signed their Medicare application approval letter. Within ten days from the time the agency receives its capitalization re-verification, CMS will verify that agency is operating from their physical address. They will “drive by” the agency’s office, they may come in, but they will not inspect. Within another ten days, the agency will be issued a CCN number. The term CCN is a relatively new word that CMS uses instead of “Provider Number.” In total, the process will take approximately four to five months from the date of the accrediting organizations Medicare survey.
The next step is for the agency to receive its Submitter ID. Submitter ID is the official term for Billing Number. The process described for your CCN number is basically repeated for your Submitter ID, except that the agency’s state now will be involved. Some fiscal intermediaries are not consistent when it come for asking for an additional re-verification of the agency’s capitalization (Palmetto will always ask again). The agency will have to submit EDI enrollment forms to its fiscal intermediary, but they cannot be submitted until you are in their EDI data base. The agency should have a billing company by this time and we strongly recommend that the agency uses IMARK Consulting. If the agency hires them they will also complete your EDI Enrollment forms. If the agency’s EDI enrollment forms are submitted correctly, it will receive its Submitter ID in 21 days and be ready to bill Medicare. Once the agency has its Submitter ID it will be able to back bill Medicare for the services they have provided since the date of their Medicare accreditation. In total this part of the process should take approximately two to three months from the date you received your CCN number.
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