As of April 8, 2008, providers must employ at least one qualified rehab technology supplier (RTS).

Cara C. Bachenheimer, JD, and David T. Williams

The quality standards incorporated in the payment policy and coverage guidelines for power mobility devices (PMDs) in November 2006 provide the National Registry of Rehabilitation Technology Suppliers (NRRTS) with an unprecedented opportunity. Providers of high-end, complex rehab and assistive technology are the first HME suppliers to be singled out by CMS for treatment as health care professionals.

The quality standards do not specifically mention NRRTS. They do refer to the assistive technology supplier (ATS) exam administered by RESNA. A member of NRRTS with a minimum of 3 years’ experience providing rehab and assistive technology is eligible to take the RESNA ATS exam. Passing this exam brings the certified rehab technology supplier (CRTS) credential administered by NRRTS.

The new quality standards require that, as of April 8, 2008, providers must employ at least one qualified rehab technology supplier (RTS) per location. The policy describes “qualified” as an individual who has passed the ATS or assistive technology practitioner (ATP) exam given by RESNA. CRTS also would be considered “qualified health care professionals” under the quality standards established for PMDs. The difference among CRTS, ATS, and ATP lies in years of experience, annual continuing education requirements, and area of focus.

It is said that if you don’t toot your own horn every once in a while, people mistake it for a spittoon. NRRTS has a solid track record of high ethical standards and has revoked the credentials of people who abuse these standards for personal or corporate financial gain. CMS needs to know this.

NRRTS must establish itself as a legitimate credentialing organization for health care professionals. CMS has provided minimum standards. Now it is up to NRRTS to prove the value of the CRTS credential.

The NRRTS requirements for the CRTS are a bit more stringent than RESNA’s, but it has not been recognized for these efforts. NRRTS has tried to make its standards known, but has largely been ignored or misunderstood. NRRTS must toot its own horn.

Currently, an individual must be a member of NRRTS for 3 years before sitting for the CRTS exam. It is assumed they will spend those 3 years under the tutelage of a CRTS learning all the nuances of rehab and assistive technology, and participating in a minimal annual continuing education program. This bar must be raised.

NRRTS raised its standards for “membership” years ago. NRRTS is a registry of people who have met very specific standards just to qualify to be included in the registry. NRRTS refers to its “members” as registrants. There are two levels of membership: registered rehab technology supplier (RRTS) and CRTS. The RRTS must be employed by a rehab supplier for 1 year before they can apply to NRRTS. Applicants must provide documentation of 15 hours of continuing education per year, have three rehab clinicians complete a written peer-review survey of their practices, and sign an agreement to abide by the NRRTS code of ethics and standards of practice. A person can’t become a member by just paying dues, he must earn it.

NRRTS issues the RRTS credential to people who “really know rehab but just can’t pass the exam,” a practice established under a “grandfathering” provision. These individuals have the requisite letters of reference, complete the annual continuing education requirements, and work under the direct supervision of a CRTS. Membership in the organization as an RRTS must be based on the assumption that individuals are qualified to take the exam—and they will take and pass the exam in an established time period after they become eligible.

Through the proposed quality standards, CMS has indicated that 10 hours of continuing education per year would be acceptable. However, 10 hours should be seen as a minimum and the credentialing body should look at a higher standard.

If CRTS want to be treated and reimbursed like the health care professionals they are, they must be prepared to train. That means developing a formal education program that, under current circumstances, could be completed during on-the-job training prior to taking the CRTS exam.

Community colleges, distance learning, and online tutorials all provide the kind of training that readily lends itself to appropriate course work. It is reasonable to assume that individuals can complete a minimum of 60 to 90 hours of course work during the 2 or 3 years working with rehab and assistive technology.

CMS will be watching to see that PMD providers perform ethically as the first HME providers to be recognized as health care professionals. Similarly, the HME industry will be watching to see how the NRRTS/CRTS model works and if it satisfies CMS. If it does, other disciplines within the HME community will quickly emulate the NRRTS example.

Cara C. Bachenheimer, JD, is VP of government relations for Invacare Corp. David T. Williams is a political and legislative strategy consultant.