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Are diabetic supplies exempt from accreditation? |
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Contrary to what many pharmacy owners believe, diabetic supplies are NOT EXEMPT from the accreditation requirement. They were only exempt from the competitive bidding process when sold at a retail outlet. Providers of mail-order diabetic supplies must still be accredited.
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Are diabetic supplies the only items for which accreditation is required? |
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No, the accreditation requirement applies to many other DMEPOS items a pharmacy may supply to a Medicare Part B patient. Some examples are: arm, leg, back, and neck braces, therapeutic shoes and inserts, crutches, canes, commode chairs, ostomy and wound care supplies, compression stockings, heat/cold applications, medical supplies, nebulizers and numerous other items.
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What about Part B drugs and vaccines? |
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Accreditation does not affect suppliers of Part B drugs, or pharmacists providing influenza and pneumonia vaccinations. They may provide these services without seeking accreditation. However, this exception is for the drugs only. If the pharmacy supplies and bills for the devices used to administer the drugs, accreditation is then required.
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When is the accreditation deadline for pharmacy? |
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Accreditaiton is required by September 30, 2009 for any pharmacy wishing to maintain its Medicare Part B billing number, regardless of its location. Those pharmacies currently seeking a new Medicare Part B billing number, mostly new pharmacies or those that have transferred ownership, must be accredited prior to applying for their number.
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What is the January 31, 2009 deadline I have heard about? |
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CMS has issued a January 31, 2009 application to the accreditation organization deadline. Pharmacies applying to an AO by this date will be guaranteed accreditation by September 30, 2009. Those applying after that date go the end of the line in priority and risk losing their Medicare Part B billing number by missing the September 30, 2009 accreditation deadline.
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I do not make much on DMEPOS and diabetic supplies so why should I accredit my pharmacies? |
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When deciding whether to accredit your pharmacy you must look at more than just the profit/loss on the DMEPOS items by themselves. It is important to look at the disease state associated with those items and determine how much a patient spends on everything else purchased at the pharmacy, from prescription drugs to OTC items. For example, look at how much money diabetic customers spent per year in the pharmacy. The average annual spend is about $5,000, which is actually close to a Roche study showing a $4,500 average annual RX spend only – BUT does not account for strips, supplies, shoes or other OTC’s. At an average gross margin of 20%, the pharmacy stands to loose $1,000 in annual profit if one patient had to go elsewhere for diabetic supplies and decide out of convenience to make all purchases at their new pharmacy. Since the pharmacy’s costs did not change, it takes the loss of less than two diabetic customers to more than pay for the annual cost of accreditation.
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I heard accreditation was delayed for two years? |
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On July 7, 2008, Congress voted to delay competitive bidding for at least 18 to 24 months even though first round contracts were to take effect July 1, 2008. Since competitive bidding and accreditation are often spoken of together, there was the assumption that accreditation was also delayed. Unfortunately, this is not the case. There is no delay for accreditation.
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Colleagues have said that pharmacy will get an exemption from accreditation since it is already highly regulated. Is this true? |
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No. Contrary to everything you may have heard there is absolutely no possibility of pharmacy receiving an exemption from accreditation. In fact, other professions who think they are now exempt just bought a short delay. CMS will not allow pharmacies, which make up over 30% of providers, to be exempt, so put that notion out of your mind.
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What about other insurers? |
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Many state Medicaid’s and private insurers have already announced that they will have the same requirements as Medicare. So, when deciding whether to accredit your pharmacy, take into consideration that the majority of third party plans will require the pharmacy to be accredited in order to continue supplying DMEPOS items to those they insure.
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All accreditation organizations CMS allows are equal so why not just use the cheapest? |
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A common myth is that all accreditation organizations are equal so, just pick the cheapest. This can be a costly mistake. The National Association of Boards of Pharmacy (NABP) for example will accredit a pharmacy at a cost of $3,050 for a three-year accreditation. However, they provide very little in the way of guidance manuals, policies or procedures, or preparation assistance and can only accredit for limited (or light) DME items. For example, if your pharmacy sells wheelchairs, NABP cannot accredit you. When choosing an Accreditation Organization, consider the cost associated with accreditation, their interpretation of the quality standards, the services they provide, the accreditation process and how long accreditation is good for before re-accreditation is required. They are not all equal.
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What does HIPAA have to do with accreditation? |
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Compliance with both the HIPAA Privacy and Security rules along with complete policies and procedures for both in conjunction with a Disaster Recovery Plan is required to pass accreditation.
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What is NASI? |
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NASI is an accreditation network of pharmacies that significantly reduces the cost of accreditation per pharmacy.
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Is NASI an Accreditation Organization (AO)? |
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No. NASI has chosen to work with the CMS-approved AO, American Board for Certification in Orthotics, Prosthetics & Pedorthics (ABCOPP) to accredit its members.
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Is the cost of the AO included in my price to join a NASI Accreditation Group? |
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Yes. The price includes the cost of the accreditation organization (AO) on-site survey. There are no annual fees and travel costs are included in the price.
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How long is the accreditation process going to take? |
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It takes approximately four to six months to complete the accreditation process. Someone in your organization will have to put in 40-60 hours of time to prepare for accreditation using the NASI Program.
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If my pharmacy is not accredited by September 30, 2009, can I become accredited after that? |
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Yes, but you will be unable to bill Medicare Part B until you become accredited.
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If I have paid for the NASI program, am I accredited? |
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No. You must complete the Network Accreditation Protocols set up by NASI in order to become accredited.
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I own four stores. Must I accredit all of my stores? |
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According to CMS Quality Standards, all DMEPOS suppliers, whether owned or subcontracted, must meet CMS Quality Standards and be separately accredited in order to bill Medicare. You are not permitted to bill supplies through one location and deliver them to another for patient dispensing. In addition, most AO’s will require that a sign be posting in the non-accredited pharmacies that states “THIS IS NOT AN ACCREDITED PHARMACY” or something similar.
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How long is my accreditation good for? |
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Depending on your accrediting organization, your accreditation is valid for two or three years. NASI Program provides a three-year accreditation.
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I am with a group, can I wait to sign-up for accreditation with NASI? |
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If you wait to start the process, you may not have time to meet the NASI Network Accreditation Protocols before the accreditation deadline.
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I have already purchased DAPP from PRS. Can I now switch to the NASI Program? |
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Yes. DAPP consists of the Policies and Procedures that are within the NASI Program. They are in different formats (DAPP on CD, NASI accessed via the internet), so you must cut and paste any completed information from DAPP into the NASI Program. You will receive a $747.00 credit towards the purchase price of the NASI Program. Depending on the AO you chose when you started the DAPP program, there may be additional Policies and Procedures in order to meet the Network Accreditation Protocols for ABCOPP, the AO that NASI has chosen. |
