AOTA Victory: Medicare Removes Certification Requirement on OT Power Wheelchair Evaluations
After more than 2 years of advocacy, AOTA is happy to announce its success in eliminating an additional requirement for occupational therapy wheelchair evaluations under Medicare. Reimbursement and Regulatory Policy staff convinced the Centers for Medicare and Medicaid Services (CMS) to eliminate a requirement that would have required an additional certification for occupational therapists (OTs) performing wheelchair evaluations for higher-end power devices.
AOTA had responded to this change, proposed to be implemented in 2008, because it caused deep concern about access for Medicare beneficiaries and an unwarranted restriction on an evaluation that is clearly within the scope of occupational therapy practice.
The provision was included in the Medicare Durable Medical Equipment (DME) contractor’s Local Coverage Determination (LCD) Policy for Power Mobility Devices (PMDs) released in 2006.
Specifically, the original LCD required that occupational therapists and physical therapists attain certification as RESNA Assistive Technology Practitioners (ATPs) in order to perform the specialty evaluation required for patients receiving Group 2, Group 3, or Group 4 power wheelchairs. The same LCD was adopted by each of the medical directors across the country, making it a national policy in effect.
Initially, AOTA voiced grave concerns that the policy, set to take effect April 1, 2008, did not measure a therapist’s competence in performing evaluations and that it would unreasonably restrict a portion of OT practice. Further, it would result in an access problem for Medicare beneficiaries because of the limited number of OTs with an ATP.
AOTA then met with the Acting Administrator of CMS, Herb Kuhn, to put these concerns forward. That was followed by a formal request for reconsideration of the LCD, including a telephone conference call with regional Medicare medical directors. On December 3, 2007, the DME medical directors told AOTA of their decision to accept AOTA’s recommendation and eliminate the requirement for RESNA ATP certification.
No additional certification for wheelchair evaluations will be required as of April 2008.
According to the ruling by the medical directors, the current requirement will remain in place, that is, the patient must have a specialty evaluation performed by a licensed/certified medical professional such as an OT or physical therapist, or by a physician who has specific training and experience in rehabilitation wheelchair evaluations. The evaluation must document the medical necessity for the wheelchair and its special features.
AOTA made the argument to CMS that the code of ethics for occupational therapy supports the expectation that an OT performing such an evaluation would only do so if she or he was competent by reason of training or experience. AOTA also reminds practitioners to be sure their competence and training is appropriate for the performance of such specialty evaluations. AOTA continues to support continuing education and training as part of a practitioner’s lifelong responsibility to provide quality services to clients.
The local DME Medicare contractors will publish an article on their individual Web sites that notifies providers of this decision. This information will also be incorporated in a future revision of the Power Mobility Devices LCD.
View the Trust Solutions (DME Jurisdiction C) Medicare Medical Director’s article regarding the policy change. Jurisdictions A, B & D will post similar letters.
View AOTA’s request for revision to the Medicare Power Mobility Devices LCD policy.