Supplier Assistive Technology Professional Involvement - JA DME
Power Mobility Devices - Supplier Assistive Technology Professional Involvement
This article clarifies the requirement in the Power Mobility Devices (PMD) Local Coverage Determination (LCD) that the supplier of a rehab PMD must employ a RESNA-certified Assistive Technology Professional (ATP) who specializes in wheelchairs and who has direct, in-person involvement in the wheelchair selection for the patient. The term rehab PMD includes Group 2 power wheelchairs (PWCs) with power seating options, all Group 3, 4, and 5 PWCs, and push-rim power assist devices.
An ATP is a designation of certification by the Rehabilitation Engineering and Assistive Technology Society of North America (RESNA). Prior to January 1, 2009, RESNA maintained two certifications – Assistive Technology Supplier (ATS) and Assistive Technology Practitioner (ATP). Those certifications were combined into one, ATP, with a single certification examination after January 1, 2009. An ATP is a service provider who analyzes the needs of individuals with disabilities, assists in the selection of appropriate equipment and trains the consumer on how to properly use the specific equipment. Leaving the company employment would not invalidate what that person did while working as a RESNA-certified ATP. The patient's record must illustrate the previously employed ATP had in-person involvement with the wheelchair selection process.
Medicare requires in person involvement in the selection of a rehab wheelchair. As one can see from the description of the ATP in Question 1, the ATP with experience and training in proper assistive technology selection is in an ideal situation to translate the functional information from the licensed certified medical professional (LCMP) specialty examination into specific equipment selection for the beneficiary. It means to physically see and interact with the patient and to document that involvement. It is important that the record show how the ATP was involved. A critical component in the provision of a PMD is ensuring that the wheelchair and accessories selected are appropriate for the beneficiary and meet their unique, individual needs. This often includes taking trunk and limb measurements, seating and positioning needs, and other observations about the beneficiary and their ability to use a PMD. This interaction should be documented by the ATP conducting the evaluation and signed and dated by the ATP, including their credentials.
The DMEPOS Quality Standards require that a supplier of complex rehab wheelchairs employ (W-2 employee) an individual who has one of the following credentials: ATP or CRTS (Certified Rehabilitative Technology Supplier). This individual may not be a "contract" employee. However, the supplier could employ additional ATPs to meet the ATP requirement in the PMD LCD. Those additional ATPs could be employed in a full-time, part-time, or contracted capacity, as is acceptable by state law. Those ATPs, if part-time or contracted, must be under the direct control of the supplier when participating in the wheelchair selection.
Involvement of the ATP in the evaluation of the patient via a live video feed is acceptable for beneficiaries who reside in remote locations as long as the evaluation is conducted in accordance with the Telehealth requirements outlined in the Centers for Medicare and Medicaid Services (CMS) Internet Only Manual (IOM), Benefit Policy Manual, 100-02, Chapter 15, Section 270. But an ATP cannot perform any part of the face to face (F2F) examination process required for all PMDs or the specialty evaluation required for rehab wheelchairs. Again, the role of the ATP is to assure that the equipment selected is appropriate to address the medical needs identified during the F2F examination and specialty evaluation process. It is inappropriate to begin product selection prior to completion of the F2F examination or specialty evaluation. Any in-person ATP/beneficiary interactions prior to the F2F examination or specialty evaluation would not be considered sufficient to meet the LCD requirement. The LCD requires that there must have been an evaluation by a properly credentialed, supplier-employed ATP. The ATP must have been certified as of the date he/she performed the in-person evaluation of the patient. The ATP is not a credentialed ATP until receipt of the credential from RESNA. The RESNA document will specify the effective date of the credential.
Medical policy does not mandate how suppliers document compliance with the ATP requirement, but there must be evidence in the supplier's file of direct in-person interaction with the patient by the ATP in the wheelchair selection process. The supplier, LCMP or treating physician must document how the ATP is involved with the patient. The documentation must be complete and detailed enough so a third party would be able to understand the nature of the ATP involvement and to show that the standard was met. Just "signing off" on a form completed by another individual would not adequately document direct, in-person involvement. For example, if the ATP participates in the specialty evaluation conducted in a multi-specialty clinic, the ATP could request that the person conducting and documenting the specialty evaluation include their name and credentials in the final report - "Ms. Jones was evaluated today for a power mobility device. Taking part in the evaluation was Dr. Smith, Ann Jones, PT, and Bill Doe, ATP from XYZ Mobility." As an alternative, the ATP can create a note documenting their involvement in the specialty evaluation process and that the recommendations reflect their input. The ATP must have direct in-person involvement with the wheelchair selection process. An ATP cannot simply "review" and "sign off" on non-credentialed staff work in order to meet the requirement.
This is a revision of an article originally published in 2008 and revised in December 2009.
- Local Coverage Determination L33789 for Power Mobility Devices [PDF]
- CMS IOM, Benefit Policy Manual, 100-02, Chapter 15, Section 270
Last Updated Wed, 05 Feb 2020 12:52:39 +0000