Frequently Asked Questions: Power Mobility Devices – ATS/ATP Requirements
The Power Mobility Devices (PMD) LCD states that wheelchairs, classified as Group 2 with a single or multiple power option, Group 3, Group 4, Group 5 and Push Rim Activated Power Assist for manual wheelchairs, must be provided by a supplier that employs a RESNA-certified Assistive Technology Supplier (ATS) or Assistive Technology Practitioner (ATP) who specializes in wheelchairs and has direct, in-person involvement in the wheelchair selection for the patient. This requirement was published in November 2006 with a prospective implementation date for PMDs delivered on or after April 1, 2008.
This FAQ will refer to both ATP and ATS credentials as ATS.
- Clarify "employ" as it relates to an ATS within
this policy.
The ATS must be employed by a supplier in a full-time, part-time, or contracted capacity as is acceptable by state law. The ATS, if part-time or contracted, must be under the direct control of the supplier.
- If a supplier has a part time or contracted ATS on staff,
what type of special documentation would be needed in an audit to
prove the credential?
A supplier must show that the employee was working under the supplier's control and guidance. The supplier should also be able to provide evidence of the ATS certification upon request.
- Would a supplier be asked to provide employment records
in an MR audit?
Yes, employment records, contracting agreements or credential records could be requested. These types of records do not need to be routinely submitted with a claim but must be available upon request.
- In the draft Supplier Standards, CMS is proposing that a
RESNA certified ATS be employed FULL-TIME by the supplier. Will the
LCD be in conflict with proposed standards?
No, there would be no conflict between the proposed supplier standards and the DME MAC policy. The proposed supplier standards specify that the supplier must employ a full time ATS, but do not require that that individual have direct, in-person involvement with each patient. If that person did have direct involvement, that would satisfy the requirements of the DME MAC LCD. However, if the supplier wanted to hire additional part-time or contracted staff, that would meet the requirements of the LCD.
- What does it mean for the ATS to have direct, in-person
involvement in the wheelchair selection process?
It means to physically see and interact with the patient face-to-face (F2F). It is important that the record show how the ATS was involved and that medical personnel drove the process.
- Can the ATS sign off on the licensed/certified medical professional
(LCMP) evaluation, detailed product description or some other attestation
to demonstrate compliance with the requirement or would an ATS/ATP
log be appropriate?
The medical directors have not mandated how suppliers document compliance with the ATS/ATP requirement. There must be evidence in the supplier's file of direct in-person interaction with the patient by the ATS in the wheelchair selection process. Suppliers must document how the ATS 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 ATS 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.
- If an ATS is involved, in person, at the time of the face-to-face
(medical) assessment and communicates with the referring clinician
during development of the specifications, does that meet the requirement?
Yes, the requirement would be met if the medical record documents their level of involvement. The ATS should also document this participation in a manner that can be verified in the event of an audit.
- Must the supplier's ATS be present for the delivery, fitting,
and/or patient training for the wheelchair provided?
The policy states the credentialed ATS must have direct, in-person involvement with equipment selection process. The policy does not require that the ATS be present for delivery, fitting, and/or patient training for the wheelchair.
- A company employs an ATS, as well as a number of non-credentialed
staff who have direct, in person involvement with the selection process.
Is it permissible for the ATS to review the staff's recommendations
and sign concurrence to meet the requirement?
Only a RESNA credentialed ATS who specializes in wheelchairs and who has direct in-person involvement with the wheelchair selection process may provide certain chairs as described in the PMD LCD as of 4/1/08. An ATS cannot simply "review" and "sign off" on non-credentialed staff work in order to meet the requirement.
- If the ATS is not present at the face-to-face examination
with the therapist or physiatrist, but does assess the patient "in
person" prior to or following the evaluation by the LCMP, such
as during the home evaluation, does this fulfill the requirement
for "involvement with the selection process"?
If the ATS has direct contact with the patient and has taken part in the wheelchair selection process, the requirement is met, providing the ATS interaction is clearly documented within the patient's file. If the ATS has not had direct in-person involvement in the wheelchair selection process, and simply delivers the ordered product, the requirement is not met and the KX modifier must NOT be added to the code.
Since the purpose of the ATS role is to assure that the equipment selected is appropriate to address the medical needs identified during the F2F examination process, it would be inappropriate to begin product selection prior to completion of the F2F examination. Any in-person ATS/beneficiary interactions prior to the F2F examination would not be considered sufficient to meet the LCD requirement. - An ATS candidate has taken the RESNA exam but as of 4/1/08 has
not yet received the credential. In the event of an audit, will the
pending receipt of the ATS credential, retroactively dated to the
day the test was taken, be considered compliant?
For a rehab power WC that is delivered on or after 4/1/08, there must have been an evaluation by a properly credentialed, supplier-employed ATS. The ATS must have been certified as of the date of he/she performed the in-person evaluation of the patient. The ATS is not a credentialed ATS until receipt of the credential from RESNA. RESNA document will specify the effective date of the credential.
- Example #1 – Physical Therapist PT takes ATS exam on 3/1. PT evaluates patient on 3/15. PMD is delivered on 4/2. RESNA notifies PT on 4/15 that he/she passed exam and was credentialed as an ATP as of 3/1 (the date of the exam). If the supplier submits the claim prior to 4/15, then a KX modifier must not be used because the result of the credentialing exam was not yet known. However, if the supplier files the claim after 4/15, then the KX modifier may be added to the code (if all other criteria are also met).
- Example #2 - PT evaluates patient on 3/1. PT takes the exam on 3/15. Even if the PT is notified that he/she passed the exam and was credentialed as of 3/15, the KX modifier cannot be added to the claim line because the PT was not credentialed by RESNA as of the date of the evaluation (3/1).
- Will a supplier, that does not have an ATS on staff as of
4/1/08, who provides a PMD requiring this credential, be in compliance
with the LCD?
No. As outlined in the Power Mobility Devices LCD, claims for Group 2 SPO or MPO, Group 3, Group 4, Group 5 and push-rim activated power assist chairs with dates of service (DOS) on or after April 1, 2008, must meet the requirement that a RESNA certified ATS has direct in-person involvement in the wheelchair selection process. In this scenario, the wheelchair would not meet coverage criteria and a KX modifier must NOT be added to the code.
- If an ATS employed by a supplier who has had direct in person
involvement in the wheelchair selection process for a patient leaves
a company before the wheelchair is delivered, will the claim be considered
compliant?
Leaving the company employment would not invalidate what that person did while working as a RESNA certified ATS. The patient's record must illustrate the previously employed ATS had in-person involvement with the wheelchair selection process.
- Can an ATP be involved in the face-to-face (F2F) examination
process, required for all PMDs, or the specialty evaluation required
for rehab power wheelchairs also perform the functions of the ATS
for the supplier of Group 2 SPO or MPO, Group 3, Group 4, Group 5
and push-rim activated power assist chairs?
For an ATP involved in the F2F examination or specialty evaluation process, it would be a conflict-of-interest to perform functions that meet the supplier requirements for an ATS to have direct in-person involvement in the Group 2 SPO or MPO, Group 3, Group 4, Group 5, and push-rim activated power assist chairs selection process.
- Will the ATS have to do the evaluation in person, or can
an evaluation be videotaped? Alternatively, if the ATS participated
in the evaluation by means of a live video feed, would that be acceptable?
Review of a live video feed or videotaped "evaluation" would NOT meet the requirements of the policy. The "direct, in-person involvement" requirement means just that - a live, in-person, interaction between the ATS and the beneficiary addressing the selection of the actual equipment to be provided is required. The goal is to assure that the items selected are those that are most appropriate to address the beneficiary's needs. Remote or indirect interactions are not considered sufficient to meet the requirement.
For more information, please refer to the Power Mobility Devices LCD
on the following link below.
http://cignagovernmentservices.com/jc/coverage/LCDinfo.html
