New JCAHO policies may affect home IV providers
New JCAHO policies may affect home IV providers
Are you eligible for survey on respiratory meds?
Joe Cabaleiro
President
Excel Consultants
Cary, NC
Many home infusion therapy providers have expanded the range of services they offer to include offering infusion in long-term care and ambulatory settings, retail pharmacy, and respiratory drugs. Most providers are aware that long term care and ambulatory infusion are already surveyable services under the Joint Commission on Accreditation of Health Care Organizations standards. As of Jan. 1, 1997, respiratory medication services also are surveyable.
The change in Joint Commission policy is a direct result of the Medicare policy revision permitting only a licensed pharmacy to bill pharmaceuticals for Medicare part B recipients.
Although the vast majority of pharmacy organizations accredited by the Joint Commission are providers of home infusion therapy, the standards have always applied to any pharmaceutical services the organization is providing to the patient in their home. As such, providers of respiratory therapy medications need to be aware that the dispensing and monitoring of these medications must meet the requirements of the Joint Commission standards.
As of Jan. 1, 1997, the Joint Commission will assign a pharmacist to survey any organization that is being surveyed for respiratory therapy services and also provides related pharmaceuticals. The pharmacist is an addition to the respiratory therapy surveyor.
Traditionally, providers of respiratory therapy have contracted with a licensed pharmacy to provide medications. The pharmacy prepares and dispenses the medications, then bills the provider who then bills Medicare. Many respiratory therapy providers have contracted with pharmacies specializing in respiratory medications to fulfill their medication needs. As of Dec. 1, 1996, this practice is no longer acceptable. If providers want to continue billing for respiratory medications, they will have to provide them through their own pharmacy.
The potential for more home infusion pharmacies to become involved in dispensing respiratory therapy products will increase as organizations pull this dispensing function "in-house."
Your organization cannot "opt out" of this survey, if it is eligible. Even if your organization uses U.S. mail, UPS, or another courier service to deliver, it would still be eligible if it meets the other requirements. Organizations providing respiratory medications will be surveyed under the same standards as any other provider of pharmaceuticals. Immediate questions most providers have when presented with this information is "How much work will be involved in this? Will we have to do assessments and care plans for the pharmaceuticals?" Most oral and respiratory medications are associated with less potential risk to the patient than intravenous medications, so the process should be less involved than the monitoring of intravenous medication use, but it will be more work than simply dispensing a retail medication, which is how such pharmaceuticals were treated in the past.
Although the applicable standards are the same, the actual process of pharmaceutical assessment and care planning may be simpler and require less time for respiratory medications. For example, it would be acceptable to develop a standardized care plan for medications such as Intal. The respiratory therapist can provide education to the patient regarding medication use based upon the care plan and act as the pharmacist’s eyes and ears in the patient’s home.
If a provider is already accredited for respiratory and pharmaceutical services, they probably already understand the principles involved. Providers accredited for respiratory therapy services and who have an associated pharmacy that has never gone through the accreditation process may be significantly impacted by this change because it will require implementation of many new processes. This may occur, for example, if a respiratory therapy provider is affiliated with a retail pharmacy.
In summary, providers of home infusion therapy services and medications should be aware that the Medicare changes may make them eligible for a pharmaceutical services survey if they dispense respiratory medications. Providers for which this change means having to spend a great deal of time, effort, and money seeking accreditation need to carefully weigh whether their volume warrants the investment in resources.
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