New Rehab Agency Accreditor Approved The Centers for Medicare and Medicaid Services (CMS) recently approved the American Association for Accreditation of Ambulatory Surgery Facilities (AAAASF) as a national accreditation program for rehabilitation agencies seeking to provide services to Medicare beneficiaries. Rehabilitation agency status allows multi-disciplinary billing by a facility or group, negating the need for ... Policy Analysis
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Policy Analysis  |   September 01, 2011
New Rehab Agency Accreditor Approved
Author Notes
  • Mark Kander, director of health care regulatory analysis, can be reached at mkander@asha.org.
    Mark Kander, director of health care regulatory analysis, can be reached at mkander@asha.org.×
Article Information
Regulatory, Legislative & Advocacy / Policy Analysis
Policy Analysis   |   September 01, 2011
New Rehab Agency Accreditor Approved
The ASHA Leader, September 2011, Vol. 16, 3. doi:10.1044/leader.PA2.16092011.3
The ASHA Leader, September 2011, Vol. 16, 3. doi:10.1044/leader.PA2.16092011.3
The Centers for Medicare and Medicaid Services (CMS) recently approved the American Association for Accreditation of Ambulatory Surgery Facilities (AAAASF) as a national accreditation program for rehabilitation agencies seeking to provide services to Medicare beneficiaries.
Rehabilitation agency status allows multi-disciplinary billing by a facility or group, negating the need for individual practitioner enrollment. Accreditation replaces the need for Medicare certification [i.e., “deemed status by a state survey agency as complying with Medicare conditions of participation” (CoP; 42 CFR, 485.701–485.729)]. Allowing AAAASF to accredit rehabilitation agencies may accelerate the Medicare approval process in states that have delays in scheduling certification surveys, usually due to underfunded state health departments.
AAAASF official standards for accreditation of rehabilitation agencies mirror the Medicare CoP. The AAAASF Medicare accreditation program has an initial four-year approval that began April 22, 2011.
AAAASF compliance also applies to state Medicaid programs that have adopted the Medicare CoP. Compliance applies to conditions of participation only and not to ownership, enrollment, or other Medicare certification requirements.
Speech-language pathologists may enroll in Medicare as private practitioners without meeting the Medicare CoP. In addition, SLPs may establish Medicare group practices, which do not need rehabilitation agency status, by completing the CMS-855B enrollment application form.
Rehabilitation agencies must comply with Medicare operational requirements (within the conditions of participation) that may entail more resources than a conventional group practice. Under Medicare CoPs, a rehabilitation agency must:
  • Establish patient care policies that are reviewed annually by one or more SLPs (and physical therapists if physical therapy services are provided) and one or more physicians associated with the agency.

  • Establish an infection control committee to develop policies and procedures for investigating, controlling, and preventing infections in the organization and to monitor staff performance to ensure that policies and procedures are executed.

  • Develop and maintain a disaster plan, with the assistance of qualified fire, safety, and other appropriate experts, to be activated in the event of fire, explosion, or other disaster.

ASHA submitted comments to CMS in response to the AAAASF certification application (The ASHA Leader, Feb. 15, 2011). Although ASHA was initially concerned about AAAASF’s familiarity with speech-language pathology and physical therapy services, ASHA is developing a collaborative relationship with this new accreditor.
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September 2011
Volume 16, Issue 9