Home Infusion Accreditation Program Matrix
Transcription
Home Infusion Accreditation Program Matrix
Home Infusion Accreditation Progr am Matrix As the home and specialty infusion market evolves within the larger health care environment, so too is the landscape of accrediting bodies and services. To keep our members abreast of all the options, NHIA recently conducted a “survey of the surveyors” to gather some basic information regarding the accreditation programs currently available in our space. Several members of the NHIA Standards and Questions Accreditation Commission for Health Care (ACHC) SEP TEMBER / OCTOBER 2015 Types of Accreditation Services Offered Is your organization Yes one of the 10 that have been deemed to accredit DMEPOS Suppliers using CMS’ Quality Standards? Is there an accreditation program for: Long Term Care (LTC) Yes Pharmacy? Home Health Nursing Yes (including Medicare Deemed Status)? Specialty Pharmacy Yes Services? Home Medical Equipment Yes (HME)/Durable ME (DME) Clinical Respiratory Yes Services? Community Pharmacy/ Yes Retail? Ambulatory Infusion Yes Center (AIC)? Any other non-pharmacy • Hospice related program(s)? • Home health therapeutic services (PT, OT, ST, MSW), compounding • Sleep lab • Behavioral health complex rehab • Fitter services • Inspection services for compounding pharmacies 34 Accreditation Standards Used Are there specific Yes, provider informs the AO and standards that apply state/federal regulatory agento infusion pharmacy cies of negative outcomes from practice? If yes, what are sanctions, regulatory inspection they? and/or audits, including: License suspension, license probation, conditions/restrictions to license, non-compliance with Medicare/ Medicaid regulations, revocation of Medicare/Medicaid/third-party provider number, any open investigation by any regulatory or governmental authority (e.g. 483’s warning letters, state Board of Pharmacy sanctions or consent orders) Specific Standards include: DRX2-6A, DRX2-6B, DRX4-7C, and DRX2-10D Center for Pharmacy Practice Accreditation (CPPA) Community Heath Accreditation Partner (CHAP) No Yes No No Yes (can be accessed using the pharmacy standards) Yes Yes Yes No Yes No Yes (addressed in HME standards) Yes (can be accessed using the pharmacy standards) No Yes No Telehealth pharmacy practice • Hospice • Private duty • Infusion therapy nursing • Public health nursing Yes, provider must comply with any federal, state, and local statutory or regulatory requirements including infusion/compounding in order to be accredited. We also request evidence of any other type of accreditation. All of our standards: Require that providers demonstrate compliance with applicable state and national regulatory requirements and/or standards established by a recognized organization appropriate for the services provided. Specialty standards: In order to provide pharmacy services beyond the borders of a pharmacy’s home state, out-of-state licensure and additional documentation may be applicable. Dispensing, wholesaling, infusion service provision and nursing services: Require individualized licensure with practice-specific oversight guiding individual practice authority. Yes, they are scattered throughout the Pharmacy Standards but refer to: DI.5c 1), 15), 17), 18), 19), 20), 21), 23), etc.; DII.5e; DII.5f; DII.5h; DII.6a2; DII.6a3; DII.8a, DII.8f; DIII.4 (all) Accreditation Committee assisted us in developing a questionnaire designed to obtain program information, such as services offered, standards, accreditation process, payer recognition, fees and terms, that providers can use as the basis for research and decision making. We appreciate the contribution of each of the accrediting bodies responding to our request. The responses appearing here have been edited for style, formatting, and length (Please see the Matrix Key on pages 42-43 for abbreviations). The original responses can be accessed on the NHIA website in the all new “Accreditation Resource Center,” available at www.nhia.org/accreditation. Please be sure to read “The Current State of Accreditation in Home and Specialty Infusion: A look at the standards and drivers in the changing alternate-site marketplace” on p. 24 for a discussion of the many changes in the accrediting landscape today, possible drivers, and things to consider when seeking accreditation and other forms of provider verification. The Compliance Team (TCT) Healthcare Quality Association on Accreditation (HQAA) The Joint Commission (TJC) National Association of Boards of Pharmacy (NABP) URAC Yes Yes Yes Yes No Yes No Yes DMEPOS only No Yes (non-Medicare only) No Yes No No Yes (specialty drug pharmacy accreditation) Yes no Yes No Yes Yes Yes Yes No Yes yes Yes DMEPOS only No Yes Yes No Yes (we administer the accreditation process for CPPA) No Yes Yes Yes (depending on eligibility) Yes • Sterile and non-sterile compounding pharmacy accreditation • Pharmacy-based travel/ retail clinic accreditation • Home infusion • Rural health clinics (CMS Deemed) • Third-party billing • Ventilator unit Yes •Verified Internet Pharmacy Practice Sites® (VIPPS®) •Veterinary-Verified Internet Pharmacy Practice Sites® (Vet-VIPPS®) •NABP e-Advertiser ApprovalCM Program •Verified-Accredited Wholesale Distributors® (VAWD®) •Verified Pharmacy Program™ (VPP™) •State-specific inspection programs • Pharmacy benefit management (PBM) • Drug therapy management • Workers compensation PBM • Mail service pharmacy • Specialty pharmacy • Community pharmacy Yes, Providers must provide a full spectrum assessment, care planning, reassessment, and performance improvement activities. No, we do not accredit infusion pharmacy practices. We do have a DMEPOS accreditation that includes infusion pump categories (with P&P that follow CMS Quality Standards) and an inspection program (VPP) that inspects general pharmacy, non-sterile compounding compliance to USP<795>, sterile compounding compliance to USP<797>, and nuclear pharmacy No Yes, specific to sterile prod- Yes, 18 standards related to uct preparation that meets infusion requirements of USP <797>; patient care plans, monitoring and follow-up; and staff competencies No Questions Accreditation Commission for Health Care (ACHC) Accreditation Standards Used (continued) Are there specific Yes, specific standards include: standards that apply to DRX2-10D, DRC4-12A, DRX4-12B, infusion nursing practice? DRX4-13B, DRX5-7C, and DRX5If yes, what are they? 17A Are there specific standards that apply to specialty pharmacy practice? If yes, what are they? Yes, in our specialty standards, relating to immune globulin therapy pre-initiation screening and patient education protocols, infusion monitoring, and adverse effect mitigation and monitoring Yes, the Infusion Therapy Nursing Standards Yes, complete set of specialty pharmacy practice standards at: www.pharmacypracticeaccredit. org No, our pharmacy standards are written broadly enough to allow for the specificity and details required Yes, see community and specialty Yes, standards incorporate indusstandards on website try trends, evidence-informed research/best practices, advances in clinical practice, and state and federal regulatory requirements Do you recommend consultants? Consultants are not needed to complete our accreditation programs No, but we provide certification courses intended only for external consultants who prepare home health and hospice providers for accreditation Every 3 years On an ongoing basis. We are currently in the process of revising all of our standards; new standards will be available for public comment in later 2015 and are scheduled for release at the end of 2016 A small group of experts in the practice area develop or review the current standards. Standards or changes are vetted with 20-30 stakeholders. Revised standards are vetted nationwide with all stakeholders; comments are considered, changes made as needed, and approved by Board of Directors. Draft standards are reviewed by applicable committees and Board. Yes Review and development draws on the evaluation of persistent gap areas or potential redundancies in current standards, changes in clinical practice, and/ or industry trends. Stakeholder input is sought including at surveys, focus groups, and via calls for public comment. The process is overseen by a Board consisting of staff and industry stakeholder groups. Yes What is the process for standards review? Are stakeholders involved? SEP TEMBER / OCTOBER 2015 Community Heath Accreditation Partner (CHAP) Do you use other standards Yes, dedicated PI measures. We and/or measures? If yes, incorporate USP 795, 797, OSHA what are they? and appropriate FDA requirements into our standards How often are your standards reviewed and updated? 36 Yes, standards are a combination of our infusion standards with additional specialty-specific requirements that refer to cost containment, REMs and limited-release medications, patient monitoring, and patient adherence Center for Pharmacy Practice Accreditation (CPPA) We offer educational tools that help with accreditation, including workshops and workbooks, and certified consultants, who have gone through an onsite training and testing (see website for listing) Standards are formally reviewed annually, but updates are only completed if required by industry regulatory changes, customer feedback, or patient/employee safety issues. We realize that every change adds internal cost to our accredited companies All standards approved by Standards and Review Committee; members are industry experts with two pharmacists When standards are Yes updated, are they provided to currently accredited pharmacies free of charge? The Compliance Team (TCT) Healthcare Quality Association on Accreditation (HQAA) The Joint Commission (TJC) Yes No Yes, standards address critiNo cal components of care and provide organizations with the flexibility to discretely define those critical competencies based on the populations they serve and the therapies that are provided Yes, specialty pharmacy No standards address: medication reconciliation, timeliness of delivery, documentation, PI measures, compounding risks, and safety No We reference recognized standards of care and measures developed by the professional associations and external stakeholder groups to promote operational effectiveness and performance excellence (i.e. NHIA, ASHP, INS, APIC, Payer measures, USP<797>, <795>, FDA, OSHA) No, customer’s unique needs determine if a consultant is needed, and the right fit for their organization Yes, CMS Quality Standards, the foundation of our DMEPOS accreditation, and VPP compounding inspections to USP<795> and <797> Yes, complete list of standards and measures at: www.urac. org/resource-center/ research-publications/ standards-and-measures-ata-glance/ No, applicants may seek a DMEPOS accreditation consultant, but we do not recommend or provide a list of accreditation consultants The DMEPOS standards were recently reviewed in Q4 2014, and are updated as needed URAC does not specifically recommend consultants, but many providers achieved accreditation with assistance from consultants Our standards are orgaNo nized operationally with Universal Standards. Our subspecialty standards address patient care plans, patient adherence, product delivery/shipping and tracking, and data reporting documentation Yes, patient satisfaction No survey standard requires providers to submit, electronically, results to be compared against many variables of the national patient satisfaction database National Association of Boards of Pharmacy (NABP) URAC Yes. Specialty Pharmacy Standards specific to specialty pharmacy practice. The hallmark module of the specialty pharmacy accreditation is the patient management section No, we provide call advisor series to assist providers with accreditation preparation It’s left up to organization Annually As needed Annually, at a minimum updated as often as appropriate based on law, regulation, and standards of practice There is a Standards Committee for the review process Yes Yes, experts in the home infusion and specialty pharmacy field, current providers and industry stakeholders regularly meet in concert w/our staff in the Division of Standard and Survey Methods throughout the year During the DMEPOS standards review session, our standards are reviewed to ensure compliance to CMS Quality Standards; stakeholders are involved and materials are continually optimized to support CMS and to meet applicant needs and expectations Our Pharmacy Advisory Group recommends changes, which then are published for public comment and are ultimately approved by the Board of Directors. Yes Yes Yes, online Yes Yes Generally, every three years with occasional changes necessitated by the environment Questions Accreditation Commission for Health Care (ACHC) Center for Pharmacy Practice Accreditation (CPPA) Community Heath Accreditation Partner (CHAP) Fees are based on the size (number of physical locations), volume and programs and services provided Total for 3-year accreditation: $3,525, broken down as: application fee: $1,000; survey fee: $1,500; survey travel fee: $500; annual participation fee year 1: $175; annual participation fee year 2: $175; annual participation fee year 3: $175. Separate fee structure applies to multisite practices—call for details Are there additional fees? If yes, for what? No Annual participation fees Estimated total cost for 3-year accreditation of a single site, single service HME, Pharmacy, or Private Duty provider: $6,635, broken down as: application fee: $605; accreditation fee: $3,510 (3 annual payments of $1,170); site visit daily rate: $1,260 (typically 2 days). Estimated total cost for 3-year accreditation of a single site, single service home health, hospice, infusion therapy nursing or public health provider serving 150 or fewer unique patients: $8,966, broken down as: application fee: $605; accreditation fee: $4,581 (3 annual payments of $1,527); site visit daily rate: $1,260 (typically 3 days) Complaint site visits: $2,000 per day; focus visits: standard site visit fee How are surveyor/ evaluator travel/meal etc. expenses paid? What are the customer’s payment options and terms? Fees are all inclusive, no addition- All fees are included in the fee al surveyor expenses structure total Fees and Terms Explain your basic fee structure--what are the criteria for your charges? And, what is the fee for each? SEP TEMBER / OCTOBER 2015 How long is the accreditation term? Accreditation Process What is the timeline to accreditation? 38 Site visitors are per diem employees and have all site visit-related fees (travel, lodging, meals) paid Several payment options: Invoice #1 - Sent with application Fees are divided into 3 annual monthly, 6-month plan, and up to (application fee plus 75% of the ac- installments. Customers are in18-month payment plan creditation fee); Invoice #2 - Sent voiced 30 days after the last day after document assessment and of site visit prior to the survey (remaining 25% of accreditation fee, fees for any additional survey sites, and first year participation fee); payment required to proceed with survey 3 years 3 years 3 years Surveys are scheduled 2-3 months from receipt of contract. Providers can also indicate a “readiness date” What accreditation decisions are possible? Accredited, Accreditation Pending, Dependent, and Denied What are the criteria for resurvey? Usually based on patient safety issues or a condition-level deficiency for home health and hospice What is the timeframe for corrective actions? 30 days Community Pharmacy: application and documentation (1 hour), document assessment (up to 90 days to submit; 3-4 weeks to review), site survey (up to 6 weeks from eligibility, post-survey notification (4-6 weeks), plan of action, if required (reviewed quarterly). Specialty Pharmacy: application and documentation (3 hours), document assessment (up to 120 days to submit; 3-4 weeks to review), site survey (up to 6 weeks from eligibility), post-survey notification (4-6 weeks), plan of action, if required (30 days). On Course for Accreditation (practice is currently going through the accreditation) and Accredited Significant non-compliance discovered on initial accreditation survey; we may verify compliance as a result of a review or because of facts which become known to us 4-9 months if no action is required See above 3-4 weeks from last day of site visit Accreditation without required action or Not Accredited (denied) A focus/follow up site visit may be required for organizations that have: high number of deficiencies, serious non-compliance with patient care, condition-level findings (home health and hospice) The Compliance Team (TCT) Healthcare Quality Association on Accreditation (HQAA) The Joint Commission (TJC) National Association of Boards of Pharmacy (NABP) URAC $7,600 (includes ambulatory suite(s) and home infusion plus DMEPOS accreditation) Fees are based upon gross revenue for Part B products; infusion is an add-on fee Fees are based on the size of the organization and scope of the services provided Fees are listed at www. nabp.net. Call our accreditation staff at 847-391-4539 for more information. Specialty Pharmacy accreditation fees are tiered, based upon an annual claim count. Organizations may obtain a quote by emailing [email protected] No response provided Application fee, monthly fee for web-based standards management (ends upon survey) Provider pays surveyor expenses No Additional fees may apply No (i.e. administrative fees for services beyond the scope of a typical accreditation) We reimburse surveyors for Expenses are included in their expenses the accreditation fee 40% of fees paid in 1st year, 30% 2nd year, 30% 3rd year Accreditation fee is invoiced at sign-up; individualized terms can be negotiated if needed Onsite survey fees are due the year that the onsite is conducted and annual fees are billed in January; individual payment options and terms available Payment for year 1 is due in full when the application is submitted Generally payment is required upon contract execution, however, payment plans may be available. 3 years 3 years 3 years 3 years 3 years 4-6 months 6 months from sign-on to accreditation Typically 3-4 months; most providers can be surveyed within 3 months of application Varies based on applicant’s preparedness and performance Varies based on the readiness of each organization; typical timeframe is 9-12 months Accreditation, Remedial Program with Corrective Action Plan Accreditation, Accreditation with Written Follow-Up, Accreditation with Focus Survey, Denial, and Revocation Deficiencies for which correction cannot be validated via written documentation Preliminary Accreditation, Accreditation, Contingent Accreditation, Denial of Accreditation Continuing accreditation operation and updating applicant file Expenses billed separately We perform a revisit for scores less then 80% 60 days 30 days on average Fees are all inclusive, no additional charge Accreditation is either Full Accreditation, Provigranted, denied, or revoked sional Accreditation, Conditional Accreditation, Corrective Action, and Denial When applicant is not Applicants are placed on familiar with or not able to “Corrective Action Status” evidence compliance with or awarded “Conditional the CMS Quality Standards Accreditation.” They must during the survey; when then submit a Corrective largely non-compliant; Action Plan followed by an or unable to remediate onsite to verify compliance issues with a manageable post-survey action plan 45-60 days, depending on Typically, 5 business days; ad- Usually 3 or 6 months the corrective action needed ditional time as appropriate Questions Accreditation Commission for Health Care (ACHC) SEP TEMBER / OCTOBER 2015 Accreditation Process (continued) How are corrective actions Template with instructions for after survey submitted to completion the AO for review? 40 Center for Pharmacy Practice Accreditation (CPPA) Community Heath Accreditation Partner (CHAP) Annual review report Though CHAPlinQ, our accreditation portal Are written materials, other than the standards, available for preparation assistance? If so, what are they? Yes, educational tools, including workshops and workbooks; certified consultants, who have gone through onsite training and testing, listed on our website Yes, document assessment tool Yes, webinars and on-demand courses How does the accredited pharmacy submit documents for pre-survey review? What is the onsite survey timeline? What is the average time from application to first day of on-site survey? Does your staff answer standards questions during preparation phase? During on-site survey? Upload to online portal Upload to a secure cloud drop box Uploaded via LinQ, our proprietary software suite Pharmacy average: 55 days Nursing average: 58 days Community: 120 days Specialty: 150 days Average is 4-6 months Yes, full-time staff to help answer Yes and Yes questions in preparation for survey Yes, Directors of Accreditations answer and interpret standards questions Does your organization provide No, but a provider could use our No customers with a policy and workbook to design P&P around procedure (P&P) manual? our standards Payer Recognition Does your accreditation meet eligibility requirements for payer program participation: Long Term Care (LTC) Yes N/A Pharmacy? Home Health Nursing Yes N/A (including Medicare Deemed Status)? Specialty Pharmacy Yes Discussions in process Services? Home Medical Equipment Yes N/A (HME)/Durable ME (DME) No, but our standards are available as a blueprint for customers to write their P&P Clinical Respiratory Services? Community Pharmacy/ Retail? Yes N/A Yes Yes Yes, standards are adaptable Ambulatory Infusion Center (AIC) Organizational Information What are your general pass/fail percentages? Yes No payers currently require accreditation for community pharmacy/retail N/A No response provided We are still early in the rollout of our accreditation programs In 2014 Home health agencies: 90% full accreditation, 4% pending, and 6% denied. Hospice facilities: 93% full accreditation, 4% pending, 4% denied. How many pharmacy surveyors are currently on staff? More than 20 No response provided 7 Are pharmacies always surveyed by a pharmacist surveyor? Yes Yes Yes Yes, standards are adaptable Yes Yes, standards are adaptable Yes No The Compliance Team (TCT) Healthcare Quality Association on Accreditation (HQAA) The Joint Commission (TJC) National Association of Boards of Pharmacy (NABP) URAC via mail or email Electronically Electronically Submitted to the assigned accreditation reviewer Yes, self assessment checklist and P&P templates Yes, blog articles, forms, checklists, outlines, and other resources Yes, document and survey guide, CMS quality standards booklet, P&P assessment, and product category checklists. U.S. mail or e-mail Electronically Electronically; occasionally we conduct an onsite verification visit (depending on the action required) Yes, overview guide, checklists, survey activity guide, access to on-demand webinars and standards experts, online leading practice library, and hot topic informational portals No pre-survey review of documents is necessary Yes, accreditation guide that lists standards and provides educational material, including interpretive information, documentation, and explanation of best practices Upload via AccreditNet, our secure web-based platform 4-6 months Average is 4 months Average is 30-60 days following qualification for survey readiness Average time from application submission to survey date is 3-5 months Yes, via implementation teleconferences and webinars Absolutely Yes, 24/7 online and by phone No, but we provide access to P&P templates No No, customers are free to use whatever P&P manual best meets their needs Yes, staff welcomes quesYes tions pre and post survey; surveyors answer basic questions onsite but do not consult on the standards or give feedback on performance during the survey Yes, new guide is targeted Yes for release Q4 2015 Yes N/A Yes Currently in review No Yes, non-Medicare only N/A Yes No No Yes N/A Yes No Yes Yes, Medicare deeming authority Yes Yes No Yes Yes Yes Yes, Medicare deeming authority; typically applications are likewise recognized by third-party payers No Yes, pharmacy services and DMEPOS Yes Yes, dependent on eligibility Currently in review No Yes N/A Yes No No Less than 5% failure rate Less than 5% failure rate A majority pass without difficulty 1 senior pharmacy advisor overseeing all Pharmacy programs 0 No- All surveyors are Expert No evaluators & are crosstrained Electronically, via email Most are able to demonstrate 100% compliance with CMS Standards within the normal accreditation timeline; applicants unable or unwilling to meet standards tend to withdraw Our pharmacy surveyor Large percentage of our cadre is growing to meet roster of nationwide surthe demands of our current veyors and new customers. Yes Surveyor assignments align with survey scope and applicant’s business model 3-4 months from application to onsite survey No In the high 90th percentile 8 A URAC survey team generally consists of a pharmacist and a nurse Questions Accreditation Commission for Health Care (ACHC) Organizational Information (continued) How many years has your 14 years organization surveyed pharmacies for clinical pharmacy standards? How many clinical More than 1,000 locations pharmacy programs are currently accredited by your organization? How many pharmacies (licensed locations) are currently accredited by your organization for DMEPOS compliance? How many nursing surveyors are currently on staff? Are nursing services always surveyed by a nurse surveyor? Who is your current President/CEO? Who is the key contact person for pharmacy accreditation? Please list contact information (phone, email, web) More than 5,000 SEP TEMBER / OCTOBER 2015 Community Heath Accreditation Partner (CHAP) 2 years at least 15 years 3 community pharmacy practices with a fourth awaiting determination and several in process; 3 specialty pharmacies in process 134 locations N/A Of the 134 above, 68 are seeking DMEPOS compliance More than 25 nursing on staff to N/A survey Yes, for home health; trained N/A pharmacists are available for infusion nursing and survey for an ambulatory infusion center Jose Domingos, CEO Lynnae Mahaney, RPh, MBA, FASHP, Executive Director 75-80 Timothy Safley, MDA, Director of Pharmacy DMEPOS and SLEEP Accreditation Patricia Foster, Account Services Representative, 855-937-2242, 919-785-3011 (fax), pfoster@achc. org. www.achc.org Tomasina Chamberlain, RN, MSN, MBA, CHPCA, Senior CP, Accreditation 202-862-34-13, [email protected], www.chapinc.org Matrix Abbreviation Key: AO accrediting organization APIC Association for Professionals in Infection Control and Epidemiology ASHP American Society of Health-System Pharmacies 42 Center for Pharmacy Practice Accreditation (CPPA) Lynnae Mahaney, RPh, MBA, FASHP, Executive Director Lynnae Mahaney, RPh, MBA, FASHP; Executive Director; 608444-7847; [email protected]; www. pharmacypracticeaccredit.org CMS FDA INS MSW Yes Karen Collishaw, CAE, President & CEO Centers for Medicare & Medicaid Services U.S. Food and Drug Administration Infusion Nurses Society medical social work 2016 Save The Date The Compliance Team (TCT) Healthcare Quality Association on Accreditation (HQAA) The Joint Commission (TJC) National Association of Boards of Pharmacy (NABP) URAC 9 years 8 years 27 years 8 years a little under 350 Choose not to answer More than 500 freestanding pharmacies + health care facility pharmacies about 2500 Choose not to answer A majority of the above organizations are dually accredited for pharmacy and DMEPOS The CPPA program’s first survey was in 2014; the first VIPPS survey was in August 1999 • 1 clinical-based pharmacy program: CPPA • 4 pharmacy based programs: DMEPOS, VIPPS, Vet-VIPPS, VPP Nearly 525 companies, representing almost 28,000 facilities are DMEPOS-accredited by NABP. 1 @ director level and 2 advisors No, it’s incorporated into entire organization not a separate program 3 More than 100 1 registered nurse N/A N/A Yes N/A N/A Sandra Canally RN, Founder & President, [email protected] Steve Simmerman, VP Operations Mary Nicholas, CEO, [email protected] Mark Chassin, MD, FACP, MPP, MPH, President Rhonda Pearce [email protected] 215-654-9110, ssimmer866.909.4722, www.hqaa. man@thecomplianceteam. org org; www.thecomplianceteam.org More than 300 pharmacy organizations are either accredited or in process N/A Carmen Catizone, MS, RPh, PD, Executive Director/ Secretary Margherita C. Labson, Exec- Nancy Tay, Accreditation utive Director Director Kylanne Green, President and CEO 630-792-5284 mlabson@ jointcommission.org 202.326.3943, [email protected] NHIA National Home Infusion Association OSHA Occupational Safety and Health Administration OT occupational therapy P&P policies and procedures Nancy Tay, Accreditation Director, 619/334-9344 [email protected] www.nabp.net Heather Bonome, PharmD, Director of Pharmacy PT physical therapy REMS risk evauation and mitigation strategy, issued by FDA ST skilled therapy NHIA Annual Conference & Exposition New Orleans, Louisiana March 21 - 24, 2016