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"I was involved" Does NOT Document ATP Direct In-Person Involvement

Posted on in Billing/Reimbursement

IWasInvolvedBy: Dan Fedor, U.S. Rehab Recently, we have seen the following denial reasons (ADMC and post-pay CERT audits) for complex rehab wheelchairs when the ATP note only stated, "I was directly involved in the selection of the wheelchair." "I was involved" is NOT sufficient! Denial Reasons from ADMC and CERT "Lack of documentation that supports the ATP has direct in-person involvement in the selection of the wheelchair." "There was no documented exam by the ATP." "The note was not signed and dated by the ATP." Per the PMD and manual wheelchair LCD, complex rehab wheelchairs (E2227, E0986, E1161, K0005, K0835 and above) require the following:

  • The wheelchair is provided by a supplier that employs a RESNA-certified Assistive Technology Professional who specializes in wheelchairs and who has direct, in-person involvement in the wheelchair selection for the beneficiary.
While DME MACs have not provided a specific form or guide as to what is expected to meet this requirement, here are some suggestions. Keep in mind that a simple statement that the ATP was involved is NOT sufficient. Expected Role of Supplier-employed ATP A supplier of complex rehab power and manual wheelchairs must employ a RESNA-certified Assistive Technology Professional who specializes in wheelchairs and who has direct, in-person involvement in the wheelchair selection process for the patient. The ATP is expected to:
  • Translate the functional information and medical justification from the therapist’s specialty examination into a specific equipment selection for the beneficiary
  • Take trunk and limb measurements and provide other observations to the therapist about the patient and their ability to use a PMD
  • The supplier-employed ATP does not document the medical necessity of the PWC or options. Medicare will not consider medical documentation provided by the supplier-employed ATP (the ATP can't write medical necessity and have an LCMP sign off).
  • Provide information on coverage criteria and suggest options that may also be covered for the patient
  • ATP interaction should be documented by the ATP conducting the evaluation and signed and dated by the ATP
  • Medical policy does not mandate how suppliers document compliance with the ATP equipment. 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 documentation must be detailed enough so a third party would be able to understand the nature of the ATP involvement 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.
A Supplier-employed ATP is NOT required to:
  • Be present for delivery
  • Be present during the fitting of the PWC
  • Be present for patient training for the PWC
For more information please contact Dan Fedor at dan.fedor@vgm.com or 844-794-8459. Click here for more articles on billing and reimbursement.

 

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