American Speech-Language-Hearing Association
December 14, 2010

Application Made by Ambulatory Surgery Association to Certify Outpatient Physical Therapy/Speech-Language Pathology Providers for Medicare or Medicaid Participation

The American Association for Accreditation of Ambulatory Surgery Facilities (AAAASF) has applied to the Centers for Medicare & Medicaid Services (CMS) for deeming status. "Deeming status" means that if a rehabilitation agency or public health agency (as a provider of speech-language pathology services) is accredited by AAAASF, the agency would be deemed to be in compliance with Medicare standards and be allowed to participate in the Medicare program. Allowing deemed status for participation in Medicaid would be at the discretion of each state Medicaid program. Public comments have been requested by CMS before it renders a final decision on the AAAASF application to allow deeming status when it accredits outpatient physical therapy providers (OPTPs) which may include speech-language pathology services. Accreditation is entirely optional for Medicare or Medicaid participation.

For Medicare purposes, the accreditation program does not apply to individual or group practices. Rather, the health care delivery organization would be a provider or agency that has facility status and is reimbursed by the "Part A" portion of Medicare Administrative Contractors. For therapy services, Medicare allows a rehabilitation agency or public health agency to provide physical therapy and/or speech-language pathology services.

What is an OPTP's alternative to accreditation by organizations such as AAAASF for Medicare participation?
State survey agencies (usually state health departments) certify an OPTP as complying with Medicare Conditions of Participation (42 CFR 485.701-.729) in order for its application to be accepted as a provider. However, an approved private accrediting organization can substitute for the state survey agency. 

Why would a provider choose a private accreditation organization rather than a state survey agency?
Private accreditation is often sought as a marketing mechanism to demonstrate to consumers that an organization other than the state government has reviewed and approved its structure and services. A facility may also seek accreditation because it believes the accrediting body's quality standards are higher than Medicare's. One benefit of private accreditation with deemed status is that there are currently many states that are not certifying rehabilitation agencies for Medicare participation because of budget constraints that have delayed state surveys by a year or more. However, the annual accreditation fee by AAAASF will range from $4,000 to $6,000, plus a $1,400 survey fee.

ASHA is conferring with other related rehabilitation organizations regarding comments to be submitted to CMS on the AAAASF application. As an accreditor of ambulatory surgical facilities, ASHA is concerned that it does not have adequate experience with speech-language pathology services. Also, the AAAASF standards adopted for PT and SLP services are exactly the same as Medicare's Conditions of Participation, 42 CFR 485. This demonstrates to ASHA that the organization has not sought input to develop higher standards or better descriptions in any area, whether administrative or clinical.

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