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For more information, please contact:
Dr. Mark McClellan
Administrator
Centers for Medicare and Medicaid Services
7500 Security Blvd
Baltimore, MD 21244
VIA ELECTRONIC MAIL: DMEPOS_Quality_Standards_Public_Comments@cms.hhs.gov
Re: The SCOOTER Store Comments on Draft Quality Standards for DMEPOS Suppliers
Dear Dr. McClellan:
On behalf of The SCOOTER Store, a nationwide supplier of power mobility equipment headquartered in New Braunfels, Texas, we appreciate the opportunity to submit comments in response to the proposed "Draft Quality Standards for Suppliers of Durable Medical Equipment, Prosthetics, Orthotics, Supplies (DMEPOS) and Other Items and Services" (Draft Quality Standards).
The SCOOTER Store was founded in 1991, has over 70 locations in 42 states, and over the past 20 years, we have worked with over 97,000 different physicians, providing power mobility products to over 205,000 disabled seniors. The SCOOTER Store's commitment to ethical and legal business practices resulted in third-party accreditation from the Accreditation Commission for Health Care, Inc. (ACHC).
While The SCOOTER Store already complies with most standards contained in this draft, we fully intend to implement the proposed Draft Quality Standards by April 1, 2006, whether or not CMS has made the standards mandatory by that time. The SCOOTER Store recommends that the Centers for Medicare and Medicaid Services (CMS) develop and mandate strong quality standards to help prevent fraud and abuse. Quality standards are the most potent weapon against opportunistic and unreliable "suppliers" who take advantage of Medicare beneficiaries. CMS should implement these Draft Quality Standards, as written, as a minimum threshold requirement in order for suppliers to participate in the Medicare program.
We believe CMS should require mandatory third-party accreditation as a requirement for all DME suppliers in the Medicare program by April of 2006. The SCOOTER Store has long advocated that accreditation be required and that such requirement would be an effective tool for CMS to use to address fraud and abuse. Allowing neutral and qualified third-parties to establish accreditation requirements has worked for other industries, like education and law, and this would be an effective tool for CMS to use to address fraud and abuse. Establishing an accreditation requirement would supplement the work of the National Supplier Clearing House by helping to ensure that only high quality organizations are allowed to participate in the Medicare program. Implementation of the requirement would be relatively easy. CMS could use the current standards developed by The Accreditation Commission for Health Care, Inc. (ACHC), Community Health Accreditation Program, Inc. (CHAPS), and The Joint Commission for Accreditation of Healthcare Organizations (JCAHO) until the Program Advisory and Oversight Committee (PAOC) and CMS finish their work to create a single set of standards.
In addition to the minimum standards CMS has proposed in the Draft Quality Standards, The SCOOTER Store offers the following recommendations to help prevent fraud and abuse in the Medicare program.
Additional Standards for Suppliers of Durable Medical Equipment:
- Require that suppliers service, with their own employees, items they sell as well as items they rent;
- Require suppliers to acquire bonds covering all employees who have face-to-face contact with Medicare Beneficiaries;
- Require that suppliers be able to respond to beneficiary needs by maintaining a physical location sufficiently close in geographic proximity to the Medicare Beneficiaries served by the supplier;
- Require that suppliers make available to CMS all serial numbers for items of DME they purchase from manufacturers and deliver to Medicare Beneficiaries;
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Require that suppliers make available to CMS, on a quarterly basis, reports showing any aberrant patterns or unusual trends with respect to the following items:
- High frequency of physician referrals by a single physician or practice group;
- Significant increases in volume/utilization of DME for any single supplier location; or
- New products the supplier has begun to sell and bill to Medicare; and
- Require that suppliers participate in an industry marketing standards organization aimed at developing guidelines for marketing DME.
- Require that suppliers maintain a minimum of $1,000,000 in comprehensive liability insurance, as opposed to the current $300,000.
We appreciate the opportunity to comment on the Draft Quality Standards and look forward to working with CMS toward our shared goal of increasing the quality of service provided to Medicare beneficiaries by the DME industry. Enacting strong quality standards provides a unique opportunity to simultaneously protect the interests of the Medicare beneficiaries and the Medicare program. As such, we firmly believe that further delay should be avoided and quality standards should be implemented immediately. Finally, we hope that CMS will consider the implementation of the recommendations in these comments in addition to the minimum requirements set out by the Draft Quality Standards.
Sincerely,
Tim Zipp
Executive Vice President,
Government Relations
The SCOOTER Store
