Power Mobility Devices FAQ – Supplier ATP Involvement (Revised July 2010)
This is a revision of an article originally published in 2008 and revised in December 2009. It 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. The response to Q3 has been revised to clarify supplier requirements relating to the DMEPOS Quality Standards.
Q1. What is an ATP?
A. An Assistive Technology Professional (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 – Assistive Technology Professional (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.
Q2. Why does Medicare require "in-person" involvement in the selection of a rehab wheelchair?
A. As one can see from the description of the ATP in Question 1, the sATP with experience and training in proper assistive technology selection is in an ideal situation to translate the functional information from the licensed certified healthcare professional (LCMP) specialty examination into a specific equipment selection for the beneficiary.
Q3. Clarify "employ" as it relates to an ATP within this policy.
A. 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 sATP requirement in the PMD LCD . Those additional sATPs could be employed in a full-time, part-time, or contracted capacity, as is acceptable by state law. Those sATPs, if part-time or contracted, must be under the direct control of the supplier when participating in the wheelchair selection.
Q4. If a supplier has a part time or contracted ATP on staff, what type of special documentation would be needed in an audit to prove the credential?
A. 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 sATP certification upon request.
Q5. Would a supplier be asked to provide employment records in an MR audit?
A. 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.
Q6. What does it mean for the sATP to have direct, in-person involvement in the wheelchair selection process?
A. It means to physically see and interact with the patient and to document that involvement. It is important that the record show how the sATP was involved.
Q7. Can the sATP sign off on the licensed/certified medical professional (LCMP) evaluation, detailed product description, or some other attestation to demonstrate compliance with the requirement?
A. The medical policy does not mandate how suppliers document compliance with the ATP requirement. There must be evidence in the supplier`s file of direct in-person interaction with the patient by the sATP in the wheelchair selection process. The supplier, LCMP or treating physician must document how the sATP 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 sATP 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 sATP participates in the specialty evaluation conducted in a multi-specialty clinic, the sATP 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,A TP from XYZ Mobility." As an alternative, the sATP can create a note documenting their involvement in the specialty evaluation process and that the recommendations reflect their input.
Q8. If the sATP is not present at the specialty evaluation with the therapist or physiatrist, but does assess the patient "in person" following the evaluation by the LCMP, such as during the home evaluation, does this fulfill the requirement for "involvement with the selection process"?
A. If the sATP has direct contact with the patient and has been involved in the wheelchair selection process, the requirement is met, providing that the sATP interaction is clearly documented within the patient`s file. If the sATP has not had direct in-person involvement in the wheelchair selection process, the requirement is not met and the KX modifier must NOT be added to the code.
Q9. How should the sATP document their involvement if their evaluation takes place at the office or the beneficiary’s home?
A. 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 sATP conducting the evaluation and signed and dated by the sATP, including their credentials.
Q10. Must the sATP be present for the delivery, fitting, and/or patient training for the wheelchair provided?
A. The policy states that the credentialed sATP must have direct, in-person involvement with the equipment selection process. The policy does not require that the sATP be present for delivery, fitting, and/or patient training for the wheelchair.
Q11. Can the sATP evaluation be conducted at the time of the PMD delivery to the beneficiary?
A. No. The purpose of the sATP evaluation is determining the proper seating, accessories and other components of the PMD prior to ordering and delivery; therefore, conducting this evaluation at the time of delivery of the device to the beneficiary’s residence is not consistent with the intent of this requirement.
Q12. A company employs an ATP, as well as a number of non-credentialed staff who have direct, in-person involvement with the selection process. Is it permissible for the sATP to review the staff`s recommendations and sign concurrence to meet the requirement?
A. The sATP must have direct in-person involvement with the wheelchair selection process. An sATP cannot simply "review" and "sign off" on non-credentialed staff work in order to meet the requirement.
Q13. Can the sATP select a product prior to the face-to-face (F2F) examination by the physician and/or prior to the specialty evaluation by the LCMP?
A. Since the role of the sATP is to assure that the equipment selected is appropriate to address the medical needs identified during the F2F examination and specialty evaluation process, it would be inappropriate to begin product selection prior to completion of the F2F examination or specialty evaluation. Any in-person sATP/beneficiary interactions prior to the F2F examination or specialty evaluation would not be considered sufficient to meet the LCD requirement.
Q14. An ATP candidate has taken the RESNA exam but at the time of the in-person evaluation has not yet received the credential. In the event of an audit, will the pending receipt of the sATP credential, retroactively dated to the day the test was taken, be considered compliant?
A. The LCD requires that there must have been an evaluation by a properly credentialed, supplier-employed ATP. The sATP must have been certified as of the date he/she performed the in-person evaluation of the patient. The sATP is not a credentialed ATP until receipt of the credential from RESNA. The RESNA document will specify the effective date of the credential.
Q15. If an ATP 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?
A. 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 sATP had in-person involvement with the wheelchair selection process.
Q16. Can an sATP perform any part of the F2F examination process required for all PMDs or the specialty evaluation required for rehab wheelchairs?
Q17. If the sATP participated in the evaluation by means of a live video feed, would that be acceptable?
A. Yes. Involvement of the sATP 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 ) Benefit Policy Manual (Internet-Only Manual 100-2), Chapter 15, Section 270.