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Facility Accreditation: The Time Is Now
By Donald O. Fedder, DrPH, FAPhA, BOCO 
Most readers are aware that in an effort to limit fraud and
abuse, 1 Congress has directed the Centers for Medicare
& Medicaid Services (CMS) to sharpen requirements to bill
Medicare. Primary among those requirements is that practitioners
must be certified or licensed to provide covered services, and the
billing facility - the supplier - must be accredited by a
CMS-approved agency. In other words, an agency that CMS has granted
deemed status.
CMS has carefully examined a number of accrediting agencies, and
the Board for Orthotist/Prosthetist Certification Inc. (BOC) is one
of just ten that have been awarded deemed status. This means that
CMS will accept BOC facility accreditation as evidence that you
qualify to bill Medicare. Since the accreditation process takes
time (think months rather than weeks!) to prepare policies,
assemble documents and other requirements, and for the accrediting
body to both review and conduct an on-site survey of your facility,
you should be getting in line now. Although we do not have exact
numbers, estimates are that about 140,000 vendors may be required
to be accredited in the next several years. Considering that there
are only ten accrediting bodies, this is a huge number to evaluate.
Let me emphasize this fact: When the CMS mandate kicks in, you will
not be able to bill Medicare unless your accreditation is in
place.
Deadlines are being phased in, and the first ten Metropolitan
Statistical Areas (MSAs) have been announced. 2 It may
be surprising to some, but the majority of facilities - even in the
initial MSAs - have not begun the accreditation process. If your
facility is in one of these MSAs, you should be working on your
accreditation application now. The next group will be announced
sometime in 2008, and it is predicted that the balance of the
country will follow along much faster. BOC reports solid market
share in this early stage of requirement, indicating early
acceptance.
What to Look for in an Accrediting Agency
Here are some basic criteria to follow when selecting an
accrediting agency. The agency's programs should be designed to
meet the needs of the beneficiaries of services first, and not a
perceived need to aggrandize either the practitioner or the
practice site. The program should be versatile and
user-friendly.
An accrediting agency's programs should be designed to meet
rigorous standards necessary to provide care with appropriate
safeguards to patients, prescribers, and payers of care. The agency
should understand the needs of injured, infirm, or otherwise
vulnerable patients. Just as you should hold your accrediting
agency to a high standard, the accrediting agency should also set a
high standard for your facility and require that it meet
performance standards in all areas of practice - not only by the
credentialed practitioners but also the entire facility staff.
And finally, the accrediting agency you choose should be
reasonably priced, both in the initial costs as well as maintenance
fees. The process should be detailed but not difficult.
The BOC accreditation program was designed by teams of
credentialing experts, facility owners/managers, practitioners,
prescribers, and representatives of the public to meet these
standards. Included in this group were representatives of small and
medium-sized practices.
I suggest downloading an application and listing the details you
will need to accumulate. Most items, such as insurance and policy
manuals, are in hand although some organization of materials will
be required. If problems arise, the BOC office stands ready to
help. Good luck, but do not procrastinate.
The time to act is now - for real!
Donald Fedder is president emeritus of the Board for
Orthotist/Prosthetist Certification Inc. (BOC) and a professor of
pharmacy and medicine at the University of Maryland, Baltimore. For
more information about BOC accreditation, visit www.bocusa.org
References
See OEI-03-07-00150. March 2007. In unannounced visits of 1,561 facilities in South Florida, 45 percent failed to meet one or more of five Medicare standards. The initial ten Metropolitan Statistical Areas (MSAs): Charlotte-Gastonia-Concord, North Carolina/South Carolina; Cincinnati-Middletown, Ohio/Kentucky/Indiana; Cleveland-Elyria-Mentor, Ohio; Dallas-Fort Worth-Arlington, Texas; Kansas City, Missouri/Kansas 
Table Of Contents - November 2007
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