Chuck,
I definitely agree that access to care is going to be an issue.  
However, the rules also state that a PM&R doctor can be responsible  
for the recommendation of equipment and, in that case, the ATP eval  
would not be needed. That's a whole other ball of wax if we then  
start delving into whether PM&R docs have any more knowledge of PMDs  
than any other type of doctor.

I do not think that the RESNA ATP certification is the be all/end all  
requirement to show competency. However, I do know that CMS was  
looking for some type of certification to show knowledge of this  
specialty area, and ATP was all they could find.

As far as the original problem, I don't think anyone has said it was  
the OT or PT causing it. I think the main problem was people having  
access to order items off of TV, getting "off the shelf" equipment  
when something more was needed, and, in general, having a vendor have  
complete control of the process with no skilled therapist  
involvement. Clients that I know personally had power chairs drop  
shipped to their homes with no in-home evaluation done, no  
instruction given, and many of those clients cannot use the PMD they  
received. Since they did receive it and Medicare did pay for it,   
however, they are stuck until the five years pass until they can get  
more appropriate equipment. There are, of course, exceptions if you  
can document a physical or medical decline or change which creates  
the need for a different type of PMD that the current chair cannot be  
adaptedd to provide. CMS is not requiring an ATP for every PMD eval.  
It is for certain types of chairs with certain types of features.

I am absolutely not saying that there is an easy answer to this  
question/dilemma, but I am frustrated that AOTA seems to be jumping  
in now that another organization has stepped up and been recognized  
by CMS. Who even knows if the rule will actually go into effect? Very  
few have, at least on the original planned date. We still have to  
make it through competitive bidding that the dealers are going  
through. I live in one of the test markets that is requiring  
competitive bids now with the anticipation that CMS will announce the  
"winning" companies that can require equipment in this area. I think  
CMS has too many things going on at once with no idea where any of  
them will lead. It is an interesting time to be in this field and  
specifically in this specialty.

Mary Alice


On Oct 30, 2007, at 3:25 PM, Chuck Willmarth wrote:

> Mary Alice,
>
> Our position is not that every OT fresh out of school can perform PMD
> evaluations.   OTs are required by state licensure laws and the  
> Code of
> Ethics to only provide those services for which they are  
> competent.  We
> do not believe that RESNA certification should be required for payment
> under Medicare.   Such a policy would put us on a slippery slope.
> Should Medicare require certification for payment when providing  
> others
> interventions such as wound care? PAMs? Should there be different
> certifications for the various practice settings?
>
> We understand that CMS wants to ensure that they are paying for  
> quality
> services provided by competent therapists.  We think that is a fine
> goal.   However we do not have information about the problem they are
> trying to solve.  If beneficiaries are getting the wrong chairs, is it
> because of the OT or PT?   Is the problem fraud?  Is the problem
> overutilization?  We don't know.  Would requiring RESNA certification
> solve the problem?  We don't think so, plus we believe that the
> certification requirement will cause a whole new set of problems
> including access to care.
>
> Chuck
>
> -----Original Message-----
> From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
> Behalf Of Mary Alice Cafiero
> Sent: Tuesday, October 30, 2007 3:43 PM
> To: OTlist@OTnow.com
> Subject: Re: [OTlist] ATP
>
> I have to say more on this subject. Sorry if I'm boring some of you!
> Unless things have changed dramatically in OT schools since I  
> graduated,
> OTs do not come out of school with knowledge of seating and  
> positioning
> or function-based wheelchair assessment. I have spoken with many
> students on their internships in the past 7-8 years, and they report
> that they still get the 1/2 to 1 day education on what a wheelchair is
> but nothing more in depth than that.
>
> Do I think OTs are the best profession ultimately to be doing this  
> type
> of assessment? Absolutely! BUT, I don't think being an OT  
> automatically
> makes you qualified to be recommending complex rehab equipment and
> advanced seating.
> RESNA respects and requires hours of direct experience in the field
> before you are even qualified to take the exam. Currently AOTA does  
> not
> have a way to acknowledge or recognize OTs that are specialists in  
> this
> field. How can AOTA expect CMS to turn to them for definitions and
> qualifications of who should be performing this type of evaluation?
>
> I'm not just trying to be stubborn and disagreeable, but this is an  
> area
> that I feel passionate about. Recommending equipment that is
> inappropriate for a client can cause harm. Recommending equipment that
> will not accommodate a client's needs for the next 4-5 years can cause
> the patient to be "stuck" because funding will not cover another
> mobility device.
>
> Mary Alice
> On Oct 30, 2007, at 2:01 PM, Chuck Willmarth wrote:
>
>>
>> I'd like to address part of this discussion.   There was no request
>> from
>> CMS to provide our qualifications to evaluate chairs prior to the LCD
>> draft issuance.  We LONG advocated for OTs to be specifically
>> recognized as qualified to do this, starting with when CMS began the
>> process of disseminating the National Coverage Decision, but CMS'
>> response to us repeatedly (in writing and on calls) was that they  
>> were
>
>> going to leave the decision of who would be qualified to another
>> process.  They didn't identify the DMERC Medical Directors as the
>> group tasked with determining who would be qualified until very late
>> in the game, a few months before the draft LCD was issued.
>>
>> We commented on the draft LCD and subsequently requested
>> reconsideration of comments.  We had a conference call with the DMERC
>> Medical Directors last week to make our case.  We should know
>> something by mid-November.
>>
>> Here are some articles that discuss the issue in more detail.
>>
>> http://www.aota.org/Archive/NewsA/FedReimbA/39756.aspx
>>
>> http://www.aota.org/News/AdvocacyNews/fedreim/39739.aspx
>>
>> http://www.aota.org/Practitioners/Reimb/News/Letters/40713.aspx
>>
>> http://www.aota.org/Practitioners/Reimb/News/Announcements/40727.aspx
>>
>>
>> Chuck Willmarth
>> Director, State Affairs and Reimbursement & Regulatory Affairs AOTA
>>
>>
>> -----Original Message-----
>> From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
>> Behalf Of Mary Alice Cafiero
>> Sent: Sunday, October 28, 2007 11:35 AM
>> To: OTlist@OTnow.com
>> Subject: Re: [OTlist] ATP
>>
>>
>>
>> Medicare first looked to AOTA and APTA to ask what the standardized
>> education and monitoring was for therapists who performed high end
>> wheelchair evaluations. Neither organization had an answer, so
>> Medicare
>> expanded it's search to RESNA (Rehab Engineering Society of North
>> America), some of the top manufacturers (Sunrise-who makes Quickie
>> chairs, Invacare, Permobil, and Pride) to ask the same questions. The
>> only credential available to show that a therapist has specific
>> knowledge of assistive technology is the ATP exam through RESNA.  
>> There
>> is also an ATS exam/credential for suppliers. RESNA requires that you
>> have a certain number of hours in the AT field before you can take  
>> the
>> exam and also requires continuing education applicable to the area in
>> which you practice to keep your credential current.
>>
>> Medicare isn't going to require an ATP for every power eval. It is
>> only
>> for Group 2 chairs with a power function such as tilt or recline
>> and any
>> Group 3 chair. Group 3 is for more complex rehab and, in my opinion,
>> should always require a therapist's evaluation.  It is a good
>> checks and
>> balances system as well as a good way for clinicians and suppliers to
>> collaborate. I personally think the therapist should be involved in
>> the
>> delivery of higher end equipment every time.
>>
>> So, after all that, my answer to your question is that, yes, it is a
>> good idea to require the ATP.
>>
>> Mary Alice Cafiero, MSOTR, ATP
>>
>>
>> On Oct 27, 2007, at 7:19 PM, Ron Carson wrote:
>>
>>> Hello All:
>>>
>>> Mary, your recent message and your credentials prompted to write  
>>> this
>>> message.
>>>
>>> Starting in 2008, Medicare will require the ATP credential for
>>> certain
>>
>>> types of wheelchair evals.
>>>
>>> How do list members feel about this?  Is an ATP credential necessary
>>> to satisfactorily evaluate a patient for power mobility?
>>>
>>> Thanks,
>>>
>>> Ron
>>>
>>>
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