xxx 1999


Facility Accreditation: ABC’s Voluntary Standards Exceed Legislated Requirements

By Mike Allen, CPO, FAAOP

The facility accreditation program of the American Board for Certification in Orthotics and Prosthetics, Inc. (ABC) remains the benchmark for the industry. Its requirements continue to serve as the standard by which other accreditation programs are measured.

An organization that has attained ABC facility accreditation demonstrates that it has voluntarily complied with standards similar to those required of practices in other health care disciplines. Its conformity to the key elements of accreditation assures the public that the organization has met the highest standards.

On the horizon
The first legislated accreditation of O&P facilities has recently appeared on the horizon.

Although licensure efforts have been continuing throughout the country in various attempts to regulate the providers of orthotic and prosthetic patient care services, Texas is the first state to mandate that organizations and facilities meet certain standards.

Following the enactment of state Senate Bill 291, Texas established its current state level accreditation standards. However, a brief examination of the state’s facility accreditation requirements reveals standards which are drastically lower than ABC’s, and also lower than other allied health accreditation programs.

Protecting the public
The public assumes individuals providing critical or ongoing care have met certain levels of qualification. They also assume they are receiving care in the most appropriate setting possible. That is why the Joint Commission on Accreditation of Healthcare Organizations (JCAHO) establishes standards for hospitals, laboratories, and other health care facilities.

However, the public must sometimes rely on governmental agencies to establish critical care standards for health care practitioners and the facilities in which that care is provided.

The Texas Board of Orthotics and Prosthetics (TBOP) promulgated rules necessary to implement legislation establishing the accreditation of prosthetic and orthotic facilities. Examination of these rules (28 TAC §821.29) reveals that the state’s mandated standards have established merely a new threshold of public protection—a bare minimum of requirements that will enable a facility to be accredited, although it does not meet the higher minimum standards of other accreditation programs in the industry.

The law was intended to establish standards that would ensure the safety, integrity, and well being of individuals receiving O&P care or services. In addition, it also should have served to protect the general public, who fund state programs such as Medicaid and vocational rehab, against fraudulent, abusive, and wasteful acts.

Unfortunately, the Texas-mandated accreditation program could force state agencies and payers, currently recognizing the requirements of ABC, to lower their program’s standards through acceptance of TBOP-promulgated rules and regulations.

The value of ABC
Throughout the years, the ABC facility accreditation program has maintained the highest—yet still reasonable—standards for organizations providing O&P patient care services. There is merit in high standards. That’s why my facilities are ABC accredited.

The value of our accreditation surpasses any others when we see the increase in the number of groups that endorse the ABC facility accreditation program. And, as expected, the number of payers who require ABC’s facility accreditation standards for consideration of payment continues to escalate, thus increasing the value even more.

There appears to be strong federal support to establish reasonable controls to reduce the wastefulness within the Health Care Financing Administration (HCFA).

Last summer, Sen. Tom Harkin (D-Iowa) introduced the "Medicare Waste Tax Reduction Act of 1999." It would, among other things, require the Health and Human Services secretary to recognize ABC facility accreditation and approve any other accreditation program that is essentially equivalent.

A dilemma in Texas
There are currently 58 facilities in Texas that are accredited by ABC. These facilities have been, or will be, undergoing the application process for mandated state accreditation. They have no choice; it is a legal requirement.

In addition to the mandated TBOP accreditation, some facilities will maintain the higher qualifications of ABC facility accreditation. Those facilities will continue to benefit from the value of ABC facility accreditation.

A few facilities may choose not to re-accredit with ABC and accept Texas’ standards as adequate. (However, that decision may not be optional, depending on the outcome of the Harkin Bill during the 106th Congress.)

Regardless of what they choose to do about ABC accreditation, all Texas facilities will be paying an additional state-assessed fee to comply with the new regulations.

In the end, ABC-accredited facilities in Texas will be faced with two programs which are very different: One is voluntary, and one mandatory; one is the benchmark and the other merely a threshold. As a consumer, which would you prefer?

Mike Allen, CPO, FAAOP, is a director on the board of ABC. He is the president of Allen Orthotics and Prosthetics Inc., in Midland, Texas.