The Complex Rehab ATS Requirement

• By Julie Piriano
• Aug 01, 2008

How should ATS/Ps document their involvement in the selection of the wheelchair with the beneficiary?

April 1, 2008, was no “Fool’s Day” for more than 3,700 RESNA-certified Assistive Technology Suppliers and Practitioners. Instead, it was the day that the Medicare Local Coverage Determination (LCD) required Group 2 power wheelchairs with single or multiple power options (all Group 3, 4 and 5 power wheelchairs and push-rim activated power assist devices) be “… provided by a supplier that employs a RESNA-certified Assistive Technology Supplier (ATS) or Assistive Technology Practitioner (ATP) who specializes in wheelchairs and who has direct, in-person involvement in the wheelchair selection for the patient.”

It should be noted that the ATP referenced in the policy refers to an individual who has passed the RESNA Assistive Technology Practitioner’s exam, has a financial stake in the provision of the equipment recommended and is participating in the evaluation process as a provider. It does not refer to a Licensed/Certified Medical Professional (LCMP), such as a PT or OT, who may also be an ATP. It would be a conflict of interest for an ATP to perform the face-to-face examination or specialty evaluation process and perform the functions that meet the supplier requirements.

LCD Requirement Prompts Questions
While the language in the LCD seemed to be very straightforward, the implementation of the ATS/P requirement and supplier’s role in the process prompted many questions. By mid-April, the medical directors had issued a FAQ that answered most questions, but no guidelines were provided regarding how ATS/Ps should document their in-person involvement in the process or their contribution in wheelchair selection with the beneficiary.

Due to the requirements set forth in the Deficit Reduction Act (DRA), the medical directors were prohibited from mandating that any specific documents be included in a beneficiary’s file or from instituting any specific documentation requirements acknowledging that the ATS/P performed the services outlined in the LCD, other than to state that “there must be evidence in the supplier’s file of direct in-person interaction with the patient by the ATS (ATP) in the wheelchair selection process.” Also, an independent review by a third party must be able to ascertain “how the ATS/P was involved and that medical personnel drove the process.”

While direct, in-person involvement means that the ATS/P “physically see and interact with the patient face-to-face,” the provider must determine what document or paperwork process they want to use internally to confirm the ATS/P’s face-to-face contact with the beneficiary, determine if they have sufficient information to append the KX modifier at claim submission, and ultimately retain payment in the event of an audit.

Many providers have created internal forms that document each face-to-face contact the ATS/P has with the beneficiary, how much time was spent, and what was done, discussed or decided during the session. The forms, which are signed and dated by the beneficiary, are kept in the supplier’s file and may document the initial needs assessment; the physical evaluation with the LCMP; simulation, demo or trial equipment sessions; a home or environmental evaluation; and training sessions that lead to the equipment selection. While the policy does not require that the ATS/P be present for the wheelchair delivery, fitting or training, many providers also have included this information on their documentation forms as a matter of best practices.

Documentation Substantiates Evaluation
When a beneficiary is evaluated at a seating and wheeled mobility clinic, it is fairly common practice for the PT or OT (LCMP) at the facility to have an evaluation form that documents the patient’s physical status, functional needs and equipment recommendations. In the team approach to equipment selection, the form is signed and dated by the beneficiary or responsible caregiver, the LCMP and the ATS/P before it is sent to the physician to review, sign and date. In this situation, the medical directors said that “just ‘signing off’ on a form completed by another individual would not adequately document direct, in-person involvement.”

Instead, it’s advisable that the provider utilize a separate charting format that clearly documents each in-person contact the ATS/P has with the beneficiary and the outcome of each session. The documentation in the patient’s medical record should corroborate the ATS/P’s involvement at the clinic, but the provider should not expect the clinic’s documentation to be the sole “proof” of their involvement in the equipment selection process. Instead, providers should develop a form to be kept in the patient’s file, which documents each in-person contact, action and outcome of the encounter. Also, the ATS/P and the beneficiary should sign and date the form to confirm participation by both parties.

If the provider can’t attend the clinic appointment but makes a separate one to perform a direct, in-person assessment before or after the LCMP evaluation, the medical directors state that “the requirement is met,” providing the ATS/P interaction is clearly documented in the patient’s file. Providers cannot perform the in-person assessment with the beneficiary prior to the date that the medical record confirms the beneficiary requires the use of a power mobility device (PMD) to complete one or more mobility-related activities of daily living. The medical directors have said, “Since the purpose of the ATS/P role is to assure that the equipment selected is appropriate to address the medical needs identified during the F2F examination process… any in-person ATS/P-beneficiary interactions prior to the F2F examination would not be considered sufficient to meet the LCD requirement.”

In October 1996, when the first RESNA test was administered, it was unclear where the ATS/P credential would lead the profession. Today the certification is clearly defined and the most successful patient outcome is the direct result of someone recognized as an expert in proper equipment use and selection.

This article originally appeared in the August 2008 issue of HME Business.