Accreditation FAQs

A moratorium is a temporary suspension or halt on the enrollment of new providers or suppliers in specific categories or geographic areas. CMS implements moratoria (plural form of moratorium) as a program integrity measure to prevent fraud, waste, and abuse (FWA) by stopping the enrollment of new providers in areas or categories where there is a significant potential for FWA.

These Moratorium FAQs were originally posted by CMS here. 

Consistent with section 1866(j)(7) of the Act, 42 CFR §424.570(a)(2) permits CMS to impose a temporary moratorium on newly enrolling Medicare providers and suppliers if, among other things, CMS determines that there is a significant potential for FWA with respect to a particular provider or supplier type, or geographic location(s), or both. 

These Moratorium FAQs were originally posted by CMS here. 

Beginning on the effective date of the moratorium, no new DMEPOS suppliers of the following types will be enrolled into Medicare: 

• Medical Supply Company,
• Medical Supply Company with Orthotics Personnel,
• Medical Supply Company with Pedorthic Personnel,
• Medical Supply Company with Prosthetics Personnel,
• Medical Supply Company with Prosthetic and Orthotic Personnel,
• Medical Supply Company with Registered Pharmacist, and
• Medical Supply Company with Respiratory Therapist

These Moratorium FAQs were originally posted by CMS here. 

 Yes. CMS imposed and extended a number of moratoria between 2013 and 2018. These applied to, at various times, home health agencies (HHAs) and ground ambulance suppliers. They were statewide or local in nature; for instance, states such as Florida, Michigan, Texas, and New Jersey had moratoria as did localities like Harris County (TX) and Broward County (FL).  These moratoria also applied to Medicaid. The last moratorium expired in 2019.

These Moratorium FAQs were originally posted by CMS here. 

CMS typically announces moratoria through:

• Federal Register notices - https://www.federalregister.gov/.
• CMS.gov website announcements - https://www.cms.gov/medicare/enrollment-renewal/providers-suppliers/chain-ownership-system-pecos/provider-enrollment-moratoria
• Communication from Medicare Administrative Contractors (MACs) and DME National Provider Enrollment (NPE) contractors
• MLN Connects newsletter – subscribe at https://public.govdelivery.com/accounts/USCMS/subscriber/new?pop=t&topic_id=USCMS_ 7819.
• Industry stakeholder notifications

These Moratorium FAQs were originally posted by CMS here. 

Providers/suppliers may use the existing appeal procedures at 42 CFR Part 498 to administratively appeal a denial of billing privileges based on the imposition of a temporary moratorium, however the scope of any such appeal would be limited solely to assessing whether the temporary moratorium applies to the provider/supplier appealing the denial. 

These Moratorium FAQs were originally posted by CMS here. 

Moratoria are implemented for six months. They can be extended for additional six-month periods if necessary. Extensions are announced through a Federal Register (FR) notice. The lifting of the moratorium will also be announced through an FR notice. 

These Moratorium FAQs were originally posted by CMS here. 

No. Moratoria typically only affect new enrollment applications. Existing enrolled providers and suppliers can generally: 

• Continue to participate in Medicare
• Submit claims for covered services
• Make certain changes to their enrollment information 

Under §424.570(a)(1)(iii), a temporary moratorium does not apply to changes in practice locations (except if the location is changing from a location outside the moratorium area to a location inside the moratorium area), changes to enrollment information (e.g., phone number), and some changes in ownership.  

In accordance with §424.570(a)(1)(iv), a moratorium does not apply to an enrollment application that has been received by the Medicare contractor prior to the date the moratorium is imposed. 

These Moratorium FAQs were originally posted by CMS here. 

Initial enrollment applications submitted during a moratorium will be denied and the application will need to be resubmitted once the moratorium is lifted. Existing providers and suppliers should continue to comply with all changes of information and revalidation reporting requirements. The moratorium only impacts new enrollments and not ongoing compliance obligations. 

These Moratorium FAQs were originally posted by CMS here. 

At this time, we believe it is in the best interest of Medicaid and CHIP beneficiaries across the country to allow each state to decide whether some form of a DMEPOS moratorium is appropriate for their respective Medicaid and CHIP programs, and the scope of any such moratorium. Each state has greater expertise and experience with their pool of DMEPOS provider types, including the requirements for each type of DMEPOS provider, than CMS. Nevertheless, CMS encourages each state to, as appropriate, implement a DMEPOS provider moratorium tailored to the specifics of their beneficiary population, as well as any geographic considerations. Additionally, CMS is offering every state and territory the opportunity to consult with CMS on the prospect of implementing a Medicaid- or CHIP-based or both DMEPOS moratorium in their jurisdictions. 

These Moratorium FAQs were originally posted by CMS here. 

Yes – Your facility must be currently seeing patients. New businesses must have a minimum of five complete patient charts, from either cash paying patients or from those wishing to use a third-party payer. However, be sure to check with the third-party payers to make sure your facility meets their requirements prior to billing.

The following documents must be uploaded and submitted with your online application.

•        All non-ABC certificates and licenses (if applicable)

•        Legal documentation of ownership (e.g., Articles of Incorporation, IRS tax form)

•        Business license, business permit or occupancy permit

•        Copy of surety bond (if applicable)

•        Your ENTIRE Policy & Procedure Manual

•        Your ENTIRE Employee Manual

•        Mission statement
  
  

These documents must be submitted within the online application portal and NOT via email, fax or regular mail. For larger documents, you can split them into multiple scanned sections. We understand that these can be very large files, but your entire P&P manual must be submitted. The submission of partial documents does not meet our requirements. If you have combined some of your documents, such as your policies, procedures and employee manuals into a single document, that is perfectly acceptable.

You must have the appropriate personnel either on staff or contracted prior to submitting your application.

You must apply for accreditation for all of the services your facility provides regardless of whether your facility is billing any third party, including Medicare/Medicaid, this requirement only applies to those services for which we offer accreditation.

If you plan to move during the reaccreditation process and have already submitted your application, you should request your survey be placed on hold. Please email accreditation@abcop.org to notify us about your address change. If your survey occurs before your move, then you must resubmit the application and fees and have another onsite survey.

If you are currently accredited and your facility has moved or is moving, please email the address change notification to accreditation@abcop.org. In your notification, please include your facility’s name, previous and new address as well as the effective date of the change.

No – you are only required to comply with the standards relevant to the services your facility provides. Please use the Custom Standards Tool to get a personalize list of standards you must comply with based on the services your facility provides.

No. CMS requires that all patient care accreditation surveys be unannounced and unscheduled.

Surveys are not conducted on federally recognized holidays or their observed days. If your facility will be closed for a state or city recognized holiday, please email us at accreditation@abcop.org.

You should have a contingency plan in place for emergencies. If your contingency plan falls through, you should place a visible note outside your door with your contact information (name, cell phone number).

No. However, someone must be available to allow the surveyor to be on site, answer questions and access documents, the owner is not required to be present.

Results are emailed 3-4 weeks after your on-site survey; hard copies are mailed out approximately 6-8 weeks after your on-site survey. If you have questions about the timeframe or have not received your results after eight weeks, please email accreditation@abcop.org with your facility’s name and address and we will resolve the issue.

All accreditations are valid for one year, and facilities are required to undergo annual surveys.

Electronic copies can be downloaded any time via the links provided in your decision email. Hard copy reprints are available for $25 each and can be ordered directly from your facility’s MY ABC account.

Privileging refers to giving an individual permission or ‘privileges’ to engage in specified clinical activities. ABC defines how a credentialed person may be allowed, under supervision, to provide items and services outside of their scope of practice. That privileging process is described in detail in the ABC Orthotic, Prosthetic and Pedorthic Scope of Practice. For the Mastectomy-only specific privileging guidelines, please refer to the Mastectomy Scope of Practice.

Certain patient care tasks can be delegated to non-credentialed individuals. The definition for Support Personnel details what aspects of patient care can be delegated to non-credentialed persons. For more information, refer to the definition of Support Personnel.

No. Off-the-shelf items can be provided by any staff member; no certification is required. Any item that has ‘off-the-shelf’ in the Medicare HCPCS L-code descriptor is considered an off-the-shelf item. This does not include diabetic HCPCS codes (e.g., A5500).

No. However, if you are required to have an additional on-site survey, you will be notified in your accreditation decision letter. Resurveys do require additional fees.

Please use our CAP template .  Your CAP should include:

• Your facility’s name and address(es)
• A written plan that address all standards marked Partially Compliant (P) or Non-Compliant (N)
• Documentation/evidence for each N and P standard
• Copies of all completed documentation (forms, patient notes, logs, training notes, etc.) showing that changes have been made. No blank templates or forms with sample data!
• Copies of any meeting minutes or agendas that show that training has been completed
• Copies of updated policies – please don’t send your entire Policy and Procedure manual only copies of the policies you have updated.

Note: If a completed annual review for your facility is part of the documentation needed for your CAP, we ask that you go ahead and perform the review with the information you have available, even if the scheduled date for that review is after your CAP deadline. This will help us better evaluate your accreditation status.

Remember - DO NOT send original documents, as items submitted to ABC will not be returned. DO make sure all PHI is blacked out before sending it to us!

Please email your CAP to accreditation@abcop.org.

Your facility’s CAP is due within 60 days of your decision email. Your deadline will be stated in your decision email and decision letter.

A document submitted to ABC demonstrating your facility’s compliance with one or more standards that were in question after your on-site survey.

ABC may request a CAP for any of the following reasons:

• You receive an overall failing score
• You receive an overall passing score but have deficiencies which require additional attention
• You miss standards that are considered mandatory, regardless of overall score. These standards are:
  • AD.5, AD.6
  • HR.6, HR.6.1
  • PC.6.9, PC.6.9.1, PC.9.1
  • PM.10
  • FS.3.2.2
  • CB.1, CB.4.1
  • HR.4.1, HR.4.2, HR.8.2, HR.8.3

If we request a CAP, your accreditation is not final until your CAP has been approved. If you fail to submit a CAP by the deadline, your existing accreditation may be revoked. You will then need to submit a new application, including all fees, for an additional on-site survey.

Address each standard marked N (Non-Compliant) or P (Partially Compliant) in the following example format:

No. You must use the format as described above. Any documentation submitted to ABC is not returned, so please do not send any Policy and Procedure manuals!

Upon receipt of your CAP, we will send you email confirmation. If you have not received an email confirmation within 48 business hours of submitting your CAP, please email us at accreditation@abcop.org.

If we need more information to make a final decision, you will have one more opportunity to submit documentation. You will receive a second request letter with a new deadline and details about what information is still needed.

It takes approximately three to four months after we receive and approve your application for the entire accreditation process from application to survey decision.

You must have the appropriate personnel either on staff or contracted prior to submitting your application.

Most CFab accreditations expire every five years. At that time, you'll need to reapply, and ABC will conduct another onsite survey.

If granted full accreditation, your accreditation will be valid for five years.

No – you are only required to comply with the standards relevant to the services your facility provides. Please use the Custom Standards Tool to get a personalize list of standards you must comply with based on the services your facility provides.

No. However, someone must be available to allow the surveyor to be on site, answer questions and access documents, the owner is not required to be present.

Results are emailed 3-4 weeks after your on-site survey; hard copies are mailed out approximately 6-8 weeks after your on-site survey. If you have questions about the timeframe or have not received your results after eight weeks, please email accreditation@abcop.org with your facility’s name and address and we will resolve the issue.

Electronic copies can be downloaded any time via the links provided in your decision email. Hard copy reprints are available for $25 each and can be ordered directly from your facility’s MY ABC account.

ABC may request a CAP for any of the following reasons:

• You receive an overall failing score
• You receive an overall passing score that falls below the passing threshold for a full five-year accreditation
• You missed standards that are considered mandatory, regardless of overall score. These standards are:

If we request a CAP, your accreditation is not final until your CAP has been approved. If you fail to submit a CAP by the deadline, your application will be denied, and any existing accreditation may be revoked. You will then need to submit a new application, including all fees, for an additional on-site survey.

No. However, if you are required to have an additional on-site survey, you will be notified in your accreditation decision letter. Resurveys do require additional fees.

Please use our CAP template .  Your CAP should include:

• Your facility’s name and address(es)
• A written plan that address all standards marked Partially Compliant (P) or Non-Compliant (N)
• Documentation/evidence for each N and P standard
• Copies of all completed documentation (forms, patient notes, logs, training notes, etc.) showing that changes have been made. No blank templates or forms with sample data!
• Copies of any meeting minutes or agendas that show that training has been completed
• Copies of updated policies – please don’t send your entire Policy and Procedure manual only copies of the policies you have updated.

Note: If a completed annual review for your facility is part of the documentation needed for your CAP, we ask that you go ahead and perform the review with the information you have available, even if the scheduled date for that review is after your CAP deadline. This will help us better evaluate your accreditation status.

Remember - DO NOT send original documents, as items submitted to ABC will not be returned. DO make sure all PHI is blacked out before sending it to us!

Please email your CAP to accreditation@abcop.org.

Upon receipt of your CAP, we will send you an email confirmation. If you have not received an email confirmation, please email us at accreditation@abcop.org.

Your facility’s CAP is due within 60 days of your decision email. Your deadline will be stated in your decision email and decision letter.

A document submitted to ABC demonstrating your facility’s compliance with one or more standards that were in question after your on-site survey.

Address each standard marked N (Non-Compliant) or P (Partially Compliant) in the following example format:

No. You must use the format as described above. Any documentation submitted to ABC is not returned, so please do not send any Policy and Procedure manuals!

If we need more information to make a final decision, you will have one more opportunity to submit documentation. You will receive a second request letter with a new deadline and details about what information is still needed.