Orthotics/Prosthetics

Albuquerque, N.M. — Chrissy Heckenberg, director of facility accreditation at the American Board for Certification in Orthotics, Prosthetics & Pedorthics, and Wendy Miller, BOCO, director of facility accreditation for BOC International, reviewed current accreditation guidelines at the Pedorthic Footcare Association 52nd Annual Symposium and Exhibition. Heckenberg and Miller discussed how facility owners and staff can prepare for the unannounced facility accreditation site survey.

“The first thing you want to do before you apply for accreditation is review all of the standards and be prepared,” Heckenberg said at the symposium. “It’s very important that you submit all of the required documentation when you submit the application. Make sure it is complete. Missing information on the application will hold up the process. We actually see this often.”

Correct deficiencies

By correctly submitting the application forms, the facility implies that it is compliant and ready for a survey. As mandated by Medicare, surveys are unannounced and unscheduled. Facilities that are reapplying should make sure they have reached out to their accrediting organization several months in advance so they have time to review the application, process it and assign a surveyor to the site. Facilities should plan ahead in case there is incomplete paperwork or an action plan is needed to correct deficiencies. If there are discrepancies, they must be resolved before the expiration date. ABC contacts facilities 8 months in advance by sending a series of emails and letters. BOC begins sending out letters 9 months in advance. BOC will send out letters 9 months, 6 months and 3 months prior to the expiration date.

“When preparing for a survey, begin with informing your staff,” Miller said. “Make sure they understand the importance of the survey. You also want them to know where to find the proper documents the surveyor may be looking for.”

Surveyors often ask to see policy procedure manuals, MSDS manuals, performance improvement reports and patient charts. Make sure those items are complete and readily available. According to Miller, performance improvement documentation will be subject to a detailed review.

“Designate a staff member to assist the surveyor,” Miller said. “Pick someone who is accountable and has the credentials to obtain the financial paperwork and patient files.”

Impeccable documentation

Miller suggested that facility staff review previously conducted surveys. Surveyors will analyze corrected actions to confirm that they are no longer an area of concern. Surveyors will also inspect every aspect of patient care documentation and sift through charts, notes and uniform documents that every facility should have and disclose to their patients.

“Documentation is the key to validation,” Heckenberg said. “Patient chart notes are the most important aspect of business. Have you documented the delivery of an item? The initial evaluation? We are looking for specific notes.”

Patient charts

Medicare introduced a quality standards booklet, DMEPOS Quality Standards Booklet, describing exactly what needs to be in patient chart notes. The booklet is a valuable guide for all facility managers, according to Heckenberg and Miller. ABC will review and confirm patient care charts by contacting patients via phone while at the facility for the survey. BOC will also gather pertinent information and interview patients who are onsite; patient phone interviews will be conducted offsite.

“This is a Medicare requirement, but we are not trying to be intrusive,” Heckenberg said. “We are calling to make sure the patient has received what he or she was billed for. Every once in a while we run into an issue. Do not panic. We call on behalf of the facility. We phrase it in a way not to alarm your patients.”

In order to avoid the inconvenience of RAC audits or increased paperwork due to incomplete records, make sure your facility is compliant and continually documenting patient care interactions.

“RAC auditors are getting a commission based on what they bring back,” Heckenberg said. “Nine out of 10 times it’s because of incomplete chart documentation. Make sure you are documenting.” — by Anthony Calabro