A New Day: Accreditation for Dialysis Facilities Presented By Curt Anliker, CEO To Florida Renal Association 2019 Annual Educational Conference · July 18-19, 2019
Today’s Topics Accreditation by an Accreditation Organization (AO) ❑ vs. Certification by the state agency Overview of NDAC’s team and service commitment ❑ Value of accreditation ❑ Future predictions ❑
What’s the Difference in Accreditation and Certification? Accreditation is awarded to a facility that ► meets the standards of the AO CMS awards certification based on the successful ► completion of an initial survey o By a state agency, or o By an AO with deemed status Certification allows for payment for care of ► Medicare beneficiaries
Are AOs CMS Contractors? ► No - All AOs are private companies ► If an AO chooses to offer “deemed status” for a provider type, they must apply for and be approved by CMS ► AOs seeking deemed status must follow CMS direction o AO Standards must be equal or more stringent o AO Survey process must be equal or more stringent
Currently Two AOs Have “Deemed Status” for ESRD ► NDAC - Approved January 4, 2019 ► Accreditation Commission for Health Care - Approved April 11, 2019
How Does the Accreditation Process Differ from a State Survey? ► A facility or provider company chooses to contract with an AO and pay for a survey under the AO standards ► The AO standards must be equivalent to the CMS regulations o May be similar to ESRD Conditions for Coverage o May include additional requirements o May be written in a different way ► AO surveys are expected to be unannounced
How Does Accreditation Differ from a State Survey? ► AO survey process: May differ from state survey process, but must be equivalent ► Survey team size: o State teams vary from 1 to 4+; o AO teams may vary from 1 to several surveyors ► Successful AO survey = recommend accreditation and deemed status for certification ► Successful state survey = recommend certification
How Does Accreditation Differ from a State Survey? ► AO survey process: May differ from state survey process, but must be equivalent ► Survey team size: o State teams vary from 1 to 4+; o AO teams may vary from 1 to several surveyors ► Successful AO survey = recommend accreditation and deemed status for certification ► Successful state survey = recommend certification Only CMS Awards Certification!
What About Findings and Corrective Action? ► AOs develop statements of findings much like the state reports ► Corrective action is required within similar timelines as the state survey ► If serious findings are identified, one or more revisits may be required to verify correction
What About Complaints? ► The AO will investigate any complaints it receives directly and referrals from the state, CMS or the Network ► CMS must authorize the state to do federal complaint investigations in dialysis facilities with deemed status ► The state will investigate complaints received by the state or CMS if the allegations indicate a serious threat to patient health and safety
AO Services Provided Geographic ✔ coverage includes entire U.S. and its territories Maximum ✔ accreditation •Initial / DeNovo period = 3 years • Re-Surveys & Expansion •Life Safety Code • Complaint Response Re-survey ✔ required to continue accreditation
Expansion of Service Surveys August 2018 CMS Guidance Letter revised some processes: ► Allows relocations, adding stations and some services to be done by “desk” review (by state or AO) ► On-site survey required to add home training or to add in-center dialysis to a home only facility o Not included in the law or the memo o 90 Day rule does not apply….. Survey may be delayed in some states
What About Resurveys? Why Stay with an AO? ► Predictable re-survey window in 33-36 months
What About Resurveys? Why Stay with an AO? ► Predictable re-survey window in 33-36 months ► An AO is customer-focused: prompt response to questions and clear communication
What About Resurveys? Why Stay with an AO? ► Predictable re-survey window in 33-36 months ► An AO is customer-focused: prompt response to questions and clear communication ► Standardization and centralized review of every survey o Thwarts “rogue citations” o Ensures consistency across the country (not just within a state)
What About Resurveys? Why Stay with an AO? ► Predictable re-survey window in 33-36 months ► An AO is customer-focused: prompt response to questions and clear communication ► Standardization and centralized review of every survey o Thwarts “rogue citations” o Ensures consistency across the country (not just within a state) ► Surveyors experienced in ESRD ► Focus on what is important for patient safety
Meet NDAC ► NDAC management and surveyors have dialysis experience ► Survey process similar to the CMS survey process ► NDAC standards closely mirror the Conditions for Coverage o Exception: cultures and endotoxin levels reflect current AAMI standards
NDAC Executive Team ► Glenda Payne : Chief Compliance Officer 40+ years in nephrology with regulatory and compliance expertise ► Jennifer Vavrinchik : Chief Operating Officer 30+ years in nephrology with clinical operations expertise ► Curt Anliker : Chief Executive Officer ~ 20 years as a dialysis provider
NDAC Advisory Board Every voice is heard! • Interdisciplinary Team •Patient •Physician •Nurses •Bio-Medical •Dietitian •Social Worker
NDAC Commitment ► Surveyors who know dialysis ► Focus on what’s important o Identify serious issues o Educate to our standards ► Identify non-compliance and require correction ► Prompt response and turn-around
Is a $14,500 Accreditation Fee Worth It?
Is a $14,500 Accreditation Fee Worth It?
Is a $14,500 Accreditation Fee Worth It? TIME = $$ 78 Days (2.6 Months) Average Time Savings = - Reduced fixed costs: Rent, utilities, insurance, capital carry costs, Med Dir fee, etc. -Reduced variable costs: Staffing + benefits, treatment supplies/drugs, labs, EMR, water and machine maintenance, social worker/dietitian -Faster Medicare reimbursement: (2.6 mo) x (12 tx/mo) x ($240/tx) = $7,500 ($7,500) x # patients = $$ INCREMENTAL REVENUE
The Future of Accreditation ► Two AOs are approved to offer this service; others may apply ► Provider interest is high ► Uptake of AO services partially depends on CMS and states’ ability to meet the mandate for prompt initial surveys ► Long-term: likely to be widely adopted ► Likely adoption/integration by payor community as accredited clinics grow
Thank you! For more information www.ndacommission.com Questions?
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