Supplier Assistive Technology Professional Involvement - JD DME
Power Mobility Devices - Supplier Assistive Technology Professional Involvement
The Power Mobility Devices (PMD) Local Coverage Determination (LCD) reasons that the supplier of a rehab PMD must employ a Rehabilitation Engineering and Assistive Technology Society of North America (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 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. A RESNA-certified ATP employee leaving the company employment does not invalidate the selection of the PMD. The patient's record must illustrate that 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. The wheelchair must be provided by a supplier that employs a RESNA-certified ATP who specializes in wheelchairs and who has direct, in-person involvement in the wheelchair selection for the beneficiary. The ATP, having 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 vital that the records show how the ATP was involved with the equipment selection.
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, noting seating and positioning needs, and making 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 an individual (W-2 employee) who has one of the following credentials: ATP or Certified Rehabilitative Technology Supplier (CRTS). This individual may not be a "contract" employee. However, the supplier may employ additional ATPs to meet the ATP requirement in the PMD LCD. Additional ATPs may 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.
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. Suppliers or their employees may not 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 are not sufficient to meet the LCD requirement.
The LCD requires that there has been an evaluation by a properly credentialed, supplier-employed ATP. The ATP must have been certified as of the date they perform the in-person evaluation of the patient. The ATP is not credentialed ATP until receipt of the credential from RESNA. The RESNA document specifies the credential effective date.
Medical policy does not mandate how suppliers document compliance with the ATP requirement however, 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 is 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 is not adequate documentation of 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, such as "Ms. Jones was evaluated today for a power mobility device. Taking part in the evaluation were Dr. Smith, Ann Jones, PT, and Bill Doe, ATP from XYZ Mobility."
Alternatively, 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 documentation to meet the ATP requirement.
This is a revision of an article originally published in 2008 and revised in November 2024.
