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DMEPOS Accreditation Deadline Extended; Pharmacies Seek Reaccreditation as New Laws Offer Limited Exemptions to Some
Originally published in the October 2010 NABP Newsletter
The deadline for durable medical equipment pharmacies to obtain durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) accreditation has been extended to January 1, 2011. This change, along with provisions that exempt some pharmacies from having to seek accreditation, is a direct result of the health care reform legislation, HR 3590, The Patient Protection and Affordable Care Act (PPACA), that was signed into law earlier this year. Section 3109(a) of the PPACA, amends subparagraph (F)(i) of section 154(b)(1)(A) of the Medicare Improvements for Patients and Providers Act of 2008 to indicate these modifications to DMEPOS accreditation requirements.
Suppliers wishing to obtain Medicare Part B billing privileges for products and services that are subject to the Centers for Medicare & Medicaid Services (CMS) quality standards are still required to obtain DMEPOS accreditation; however, the PPACA exempts pharmacies that already have such privileges if they meet certain criteria. According to the PPACA, to qualify for exemption by January 1, 2011, a pharmacy must meet all of the following criteria:
- the total billings by the pharmacy for DMEPOS are less than 5% of total pharmacy sales for the previous three calendar years;
- the pharmacy has been enrolled as a supplier of DMEPOS and has been issued a National Supplier Clearinghouse (NSC) provider number for at least five years;
- no final adverse action has been imposed on the pharmacy in the past five years;
- the pharmacy submits an attestation, in the manner and at the time frame to be determined, that the pharmacy meets the criteria listed in 1-3; and
- the pharmacy agrees to submit materials as requested during the course of an audit conducted on a random sample of pharmacies selected annually.
CMS further discusses these criteria in its fact sheet, stressing that criterion No. 1 pertains specifically to total pharmacy revenue. If a pharmacy is part of a larger facility, such as a grocery store, the total DMEPOS sales would have to be less than 5% of the total pharmacy sales, not of the total grocery store sales, in order for the pharmacy to be exempt from accreditation. Newly opened pharmacy locations are automatically required to be accredited by the January 1, 2011 deadline as they do not meet the five-year requirement stated in exemption criterion No. 2.
Status of DMEPOS Accreditations
Despite the enactment of the PPACA, NABP continues to receive new DMEPOS accreditation applications as well as requests for reaccreditation. Of the 25 suppliers who obtained accreditation from the Association in 2007 when the program first began, nearly 70% have opted for reaccreditation. These suppliers are composed of both independent and chain pharmacies. Requirements that may be driving suppliers to seek reaccreditation may include:
- Those set by CMS in order to participate in the competitive bidding process
- Those set by third-party insurance providers
- Those necessary to obtain an NSC number in order to bill for Medicare
Tim Cady, president of Advanced Diabetes Supply, says he never really thought about not obtaining reaccreditation. He explains that Advance Diabetes Supply deals with a lot of Medicare Part B services and in order to bill for these services they must be accredited. Advanced Diabetes Supply was first awarded DMEPOS accreditation by NABP in 2007 and obtained reaccreditation earlier this year. “Accreditation holds us to a higher standard,” Cady states.
According to Cady, another motive for seeking accreditation was for managed care reasons. “We are finding that more and more managed care organizations are asking for accredited suppliers,” he says. Cady explains that accreditation is becoming a standard of care for pharmacies and others who provide durable medical equipment. Like Advanced Diabetes Supply, CVS/pharmacy and Walgreen Co first received DMEPOS accreditation from NABP in 2007 and are both currently undergoing the DMEPOS reaccreditation process. Gregory Sciarra, RPh, director of pharmacy operations at CVS/pharmacy, explains that DMEPOS accreditation “adds credibility to our services while providing us latitude to pursue different opportunities with Medicare.” Sciarra continues, “accreditation provides an additional level of comfort to our Medicare beneficiaries.”
According to Ric Leonardi, RPh, director of Medicare Part B at Walgreen Co, based on the rules written, he felt that as a large chain, Walgreens needed to obtain accreditation. Similar to Cady’s earlier statement, Leonardi also explains, “certain state Medicaid programs have tacked on to the Medicare accreditation movement and have begun requiring that pharmacies be accredited in order to bill.”
Suppliers that are obtaining and maintaining DMEPOS accreditation are doing their part to ensure that Medicare beneficiaries receive the products, services, and patient care they deserve. With more than 100 years of experience in pharmacy, NABP shares this ultimate goal and remains committed to protecting the public health through its DMEPOS accreditation program. More information on the DMEPOS accreditation program is available on the NABP Web site.
