Home Health & Hospice Week

'Little' changes could cause big headaches, experts say.

Suppliers of home medical equipment won't want to miss the chance to comment on these potentially problematic provisions of the feds' new rule on HME enrollment standards.

In addition to adding five new enrollment standards, the Jan. 25 rule makes a number of changes to existing standards. These changes include:

• Bricks and mortar. Under the proposed rule, suppliers would have to maintain a location or office at an appropriate site where they store business records and retain documentation of orders and referrals. One potential headache is the rule's take on appropriate signage.

"We believe that all DMEPOS suppliers must have a permanent, durable sign that is visible at the main entrance of the facility and positioned so that it is visible to the public, including customers using wheelchairs," says the rule.

"That's a landlord issue," charges Mary Ellen Conway, president of Capital Healthcare Group in Bethesda, MD. Tenants have to abide by private restrictions about signage that could conflict with CMS' rule, she notes.

• Insurance requirements. Suppliers would have to list the National Supplier Clearinghouse as a certificate holder on their comprehensive liability insurance policies. The industry should carefully consider the costs that the proposed changes could bring, says the Power Mobility Coalition's Eric Sokol.

• Contracted staff. The proposed rule calls on suppliers to hire as W-2 employees all licensed personnel, including registered nurses and respiratory therapists.

The requirement that suppliers hire, rather than contract with, respiratory therapists would likely be one of the most problematic changes, predicts Conway. Small companies can't keep a respiratory therapist busy 40 hours a week, and most respiratory therapists aren't looking for part-time jobs without benefits, she explains.