The Centers for Medicare & Medicaid Services (CMS) recently finalized new requirements that significantly change how Accrediting Organizations (AOs) and their affiliated consulting entities interact with healthcare providers and suppliers seeking accreditation. CMS designed these changes to strengthen oversight, reduce potential conflicts of interest, and reinforce the accreditation process’s independence. For behavioral health organizations, psychiatric hospitals, and other accredited healthcare providers these changes may affect how they obtain accreditation readiness support in the future.
Key Takeaways
- CMS finalized new requirements that restrict consulting services provided by Accrediting Organizations and affiliated consulting entities.
- Accrediting Organizations may no longer provide fee-based consulting before an initial accreditation survey or during the 12 months preceding a reaccreditation survey.
- Accrediting Organizations are prohibited from providing consulting services related to complaints involving organizations they accredit.
- New firewall, conflict-of-interest, and reporting requirements are intended to strengthen the independence of accreditation decisions.
- Independent consulting firms are not subject to these AO-specific restrictions and may continue to provide accreditation readiness assessments, mock surveys, regulatory consulting, performance improvement, and sustained compliance support.
What Changes Did CMS Make to Accrediting Organization Consulting Services?
1) Can Accrediting Organizations Provide Consulting Before an Initial Survey?
No. Accrediting Organizations and affiliated consulting entities may no longer provide fee-based consulting services to an organization before its initial accreditation survey. Organizations seeking first-time accreditation may need to identify independent resources to help assess readiness, close compliance gaps, and prepare staff for survey activities.
2) Can Accrediting Organizations Provide Consulting Before a Reaccreditation Survey?
No. The rule prohibits Accrediting Organizations from providing consulting services during the 12 months immediately preceding a expected reaccreditation survey.
This creates a clear separation between accreditation preparation and the accreditation decision-making process.
3) Can Accrediting Organizations Provide Consulting Related to Complaints?
No. Accrediting Organizations may not provide consulting services in response to complaints involving organizations they accredit.
Healthcare organizations facing complaint investigations or regulatory concerns may need to seek assistance from independent experts who are not involved in accreditation oversight.
What Has Not Changed
Healthcare organizations still need expert guidance to prepare for surveys, interpret changing regulatory requirements, conduct mock surveys, and develop sustainable compliance programs.
What has changed is who can provide that support.
Independent consulting firms are not subject to these Accrediting Organization restrictions and can continue to provide accreditation readiness assessments, mock surveys, regulatory consulting, leadership education, and performance improvement support.
Healthcare organizations should evaluate how these changes may affect their accreditation preparation strategy and consulting relationships. Identifying an independent consulting partner that can assist you throughout the accreditation cycle and in times of regulatory challenges and threats is more critical than ever.
Why Independent Consulting Matters More Than Ever
The new CMS requirements create a clearer distinction between accreditation oversight and accreditation preparation.
Independent consulting firms offer several advantages:
- Continuity in advising services throughout the survey cycle
- Objective assessments of organizational readiness
- Mock surveys that simulate actual survey conditions
- Assistance interpreting evolving CMS and accreditation requirements
- Action plans focused on sustainable compliance improvement
For many organizations, this separation may provide greater confidence that readiness assessments and recommendations are based solely on improving performance and compliance.
How Barrins & Associates Can Help
Barrins & Associates has long operated independently of accrediting organizations.
Our consultants help healthcare organizations identify risks, strengthen compliance programs, educate staff, prepare leaders for surveys, and build sustainable processes that support long-term success.
As CMS increases oversight of accrediting organizations and the Joint Commission expands Accreditation 360, healthcare organizations are entering a new era of survey readiness. Independent assessments, objective guidance, and continuous compliance strategies are becoming increasingly important components of successful accreditation programs.
Whether your organization is preparing for an initial survey, a reaccreditation or extension survey, a behavioral health survey, a CMS validation survey, or addressing specific regulatory challenges, our team can provide objective guidance tailored to your organization’s needs.
Schedule a Discussion
If you would like to discuss how these new requirements may impact your organization, schedule a complimentary consultation with our team.
We can help you understand the implications of the CMS rule, evaluate your current readiness approach, and identify opportunities to strengthen compliance and survey preparedness.
Contact Barrins & Associates today to schedule a confidential discussion.