June 6, 2012
New AAAASF Accreditation Option for RHCs
Summary
On May 25, 2012, the Centers for Medicare and Medicaid Services ("CMS") issued a Survey & Certification Letter (S&C: 12-33-AO) sent to all state survey agencies announcing its decision to approve the American Association for Accreditation of Ambulatory Surgery Facilities ("AAAASF") for recognition as a national accreditation program for rural health clinics ("RHCs") seeking to participate in the Medicare and Medicaid programs. CMS' review determined that AAAASF's accreditation program for RHCs meets or exceeds the Medicare Conditions for Certification. The initial approval period is four years from March 23, 2012 through March 23, 2016. Further, effective May 23, 2012, RHCs accredited by the AAAASF for purposes of Medicare participation may be "deemed" by CMS to meet the Medicare Conditions for Certification. RHCs now have an alternate path, previously unavailable, to obtain accreditation and to achieve "deemed status" under the Medicare and Medicaid programs. However, deeming authority for this program is limited to the Medicare Conditions for Certification and does not apply to ownership, enrollment or other Medicare certification requirements.
Background
Section 1865(a) of the Social Security Act permits CMS to recognize national accrediting organizations ("AO") that demonstrate that their health and safety standards and oversight processes meet or surpass the CMS Conditions of Participation, Conditions for Coverage or Conditions for Certification, as applicable ("Medicare Standards"). A provider or supplier accredited by a CMS-approved AO is "deemed" to meet Medicare Standards. The provider or supplier is then under the jurisdiction of the AO and need not be surveyed by a state survey agency ("SA") unless the SA receives a complaint about the organization or decides to conduct a validation survey. RHCs may now apply to become accredited by the AAAASF and no longer need rely on the SA for certification and recertification.
Practical Considerations
RHCs seeking an initial certification survey for participation in Medicare should strongly consider obtaining certification through accreditation by AAAASF. Likely, this will be the quickest means to certification. CMS has specifically stated that where a provider or supplier has a CMS-approved accreditation option, initial certification surveys by SAs become low priority. Currently enrolled RHCs choosing to become accredited by AAAASF need not submit an updated CMS-855 form.
The Survey and Certification Letter, including a list of helpful FAQs, can be found here. If you have any questions or would like additional information about this topic, please contact:
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