Switching Accreditors: Will it Interrupt Medicare Reimbursement?

For the first time, there are three separate entities that hospitals can turn to for accreditation—the ubiquitous Joint Commission, the Healthcare Facilities Accreditation Program (HFAP), and newcomer Det Norske Veritas' (DNV) National Integrated Accreditation for Healthcare Organizations (NIAHO) program. With the option to move from one accreditation organization (AO) to another comes concerns of process and Medicare reimbursement.

"One of the issues that keeps coming up is, if I switch AOs, will that impact my Medicare reimbursement?" says Darrel Scott, senior vice president for regulatory and legal affairs for DNV.

To address this concern, DNV recently updated its FAQs to describe the process of switching accreditors.

"This applies regardless of which AO you are changing from or going to," says Scott. "We wanted to try to address in our FAQs the exact mechanic that occurs when a move is made."

So here's the process: when a hospital or hospital system decides to switch accreditation organizations, it can notify its current AO right away. The next step could go one of two different ways. First, the hospital and the AO can work out a plan for withdrawal and transition to the new AO. If this does not happen—that is, if the hospital and the AO cannot work out a transition strategy, the current AO may immediately withdraw the hospital's accreditation.

This is not as problematic as it may seem, however. The hospital's Medicare provider agreement is not affected should the current AO withdraw its accreditation before it is accredited by another AO. The current AO will, after removing the hospital's accreditation, notify the CMS Central Office and the applicable CMS Regional Office of its action. The AO will also provide those offices with an effective date of termination.

Again, there are two ways this next step can go. The simpler way is if the termination of one accreditation organization's accreditation is concurrent with a new recommendation for accredited, deemed status by the AO the hospital is transferring to. In that case, the hospital is simply transferred under the umbrella of the new AO.

However, if the current AO withdraws its accreditation and the hospital has not yet received accreditation from the new AO, the hospital is placed under the State Survey Agency (SA) jurisdiction. The hospital will remain under SA jurisdiction until it receives accredited, deemed status from the new organization. This new accreditation and deemed status must, of course, be approved by the CMS Central Office and the applicable CMS Regional Office as well.

"If the current AO informs the hospital that it is terminating its accreditation immediately and the AO notifies CMS, the hospital is moved over to the jurisdiction of the State Survey Agency," says Scott. "The hospital is then subject to a state survey until it is accredited by the new AO."

Throughout this process, the hospital's Medicare provider agreement and reimbursement is uninterrupted even though the hospital may be in transition from one AO to another. During this transition, there is always oversight from one of these entities and Medicare reimbursement is not affected.