The Medicare requirement of direct involvement from an ATS or ATP will forever alter the way rehab business is conducted.
April 1 has come and gone, and once again the rules have changed. What is taking place within the industry is nothing short of a revolutionary change that is altering the image, criteria, and process of complex rehab power mobility. The newly established Medicare supplier requirement of direct involvement from an assistive technology supplier (ATS) or assistive technology practitioner (ATP)—as well as the upcoming implementation of competitive bidding—are poised to forever alter the way rehab business is conducted.
Under CMS' new regulations for providing power mobility devices (PMDs) of Group 2 single power coding and higher, RESNA certification is required. The requirement states that the product must be provided by a supplier that employs a RESNA-certified ATS or ATP who specializes in wheelchairs, and who has direct, in-person involvement in the wheelchair selection for the patient.
There are no provisions in place limiting the type of employment of the ATS/ATP to full time, part time, or even on a per diem or contractual basis (and this absence of provisions is being scrutinized). Without more clarification from CMS, the scary possibility exists that an ATS/ATP who works for a manufacturer could provide these services. This requirement is currently retained, and is effective for claims with dates of service on or after April 1, 2008.
The RESNA credentialing program, the industry's first step toward implementing a provider requirement for individual certification, was designed to provide anyone practicing in the area of assistive technology (AT) with a basic knowledge of these technologies and how they interface to maximize function. Professionals involved in the provision of AT services, specifically those addressing seating and mobility needs, can best serve their clients by having a working knowledge of the available options and how and when to refer them to other practitioners.
It is widely accepted that earning a RESNA credential delivers increased credibility to the provider and is a step in the right direction for the industry as a whole. The ATS/ATP credentials also promote quality assurance for the beneficiary, and a higher professional standard in the AT service provision. As many know, receiving that RESNA certification can be easier said than done.
To obtain the RESNA ATS or ATP certification, candidates must first determine their eligibility by reviewing RESNA's eligibility requirements. If they meet the requirements, they must select an examination date and location, and complete an application form that requires educational and training documentation, a completed form from a supervisor, and a $500 fee. If the application has been approved and accepted, the next step is to thoroughly prepare for and (hopefully) pass the exam.
While described as "basic knowledge" by RESNA, the ATS/ATP exam can be, for some, a rigorous test on a broad spectrum of topics ranging from ECUs and computer access to augmentative communication and ergonomics. RESNA's ATS/ATP certification passing rate for 2007 was approximately 45% for ATS and 85% for ATP, which speaks to the need for more high-quality educational curriculums being available to suppliers. A 69% on the exam will earn a passing grade, or 138 of the 200 multiple choice questions answered correctly.
Following CMS' lead, other funding sources are likely to implement similar policies, and the rehab industry should see significant attrition over the next 18 to 24 months. Complex rehab providers are responding to the ATS/ATP requirements in many ways.
- Providers that have long recognized the importance of certification already have qualified staff in place, as well as an internal process that promotes the training and education necessary for the RESNA certification process. While the certification may be new to some, most of the top rehab providers in the business have been touting ATS/ATP behind their names for years.
- Providers that service complex rehab clients, but are not yet certified, seem to be divided into two groups—those that are preparing to initiate the certification process, or are currently involved in it, and those still trying to figure out how to comply with the ATS/ATP requirement. With some providers indicating they may not seek ATS/ATP certification, it seems as though we will see attrition among complex rehab providers. This will generate opportunities for providers with ATSs on staff.
- Some providers currently operating without certification, who occasionally service rehab clients (not as part of their core business), have no intention of becoming certified.
It is evident that there could be more business being funneled to the top rehab providers throughout the nation. These companies have been perfecting their business model for years with long-standing clinical relationships and ATS/ATP certified sales staff. "So much of what we do is personal," says Georgie Blackburn, vice president of government relations for Blackburn's, Tarentum, Pa. "It is important that we do it well, because we're accountable to that patient. And the RESNA ATS or ATP credential is a direct conduit to accountability."
COMPETITIVE BIDDING
Among the myriad issues with the competitive bidding program, including bid winners who do not have to have a physical location with posted hours, and do not have to service the products they sell, lies the additional issue of manufacturers supplying equipment outside the "winner's" core competency. An example of this would be if a large respiratory provider wins a complex rehab contract. Will manufacturers sell and supply products to these providers, and will the integrity and safety of the market be put at risk by lack of focus on experience and adherence to written provider standards? We believe that published provider standards developed by manufacturers go a long way in protecting both the integrity of the industry as well as the consumers' best interests. Unfortunately, not all manufacturers have published standards, and that could lead to unqualified providers delivering complex rehab.
Quantum Rehab recently revised its standards to reflect this new requirement. While Quantum Rehab fully endorses the Medicare policy for the provision of complex rehab products, we also realize that these patients are not just Medicare beneficiaries. In fact, we estimate Medicare comprises about 25%, while the remainder consists of Medicaid, private insurance, workers' compensation, VA medical centers, and other funding sources that do not have this requirement in place as of yet. "I'm pleased that Pride took an additional step in developing specific standards for providers of their Group 2 with one power option and above products as well as all Quantum products," Blackburn adds. "Competitive bidding has diminished �choice' for the Medicare beneficiary. It should not diminish quality, and the Quantum standards underscore that. Our Tarentum location has four ATSs, one who is a COTA/L, and our Erie location has two. Some of our present and past ATSs earned their credentials almost 10 years ago—we thought it extremely important to do so. I'm glad we're partners with a manufacturer that thinks the same way."
Pride will continue to offer providers and their staff the tools they need to become better prepared through its education team. Since 1999, we've been helping our providers with the challenges of the RESNA exam, and introduced a RESNA prep course in 2005. The class, available as part of Pride's Annual Seminar Tour, covers key areas of product knowledge, ECUs, augmentative communication, computer access, and funding sources and legislation topics. Additionally, standardized test-taking skills are reviewed and a timed practice exam is administered to the class and reviewed by the instructor.
Tools and Tactics
- Under CMS' new regulations for providing PMDs of Group 2 single power coding and higher, RESNA certification is required.
- Be aware of the looming approach of attrition in the complex rehab market.
- Since some providers may not seek ATS/ATP certification, opportunities for providers with ATSs/ATPs on staff could materialize.
It is highly important that providers realize ATS/ATP certification is granted to a person, not a company, so resources like the educational opportunities we provide are helpful to maintain certified staff members through employee turnover that may occur over a period of time. Internal education departments are also recommended for providers.
As an industry, providers and manufacturers alike should be aware of the looming approach of attrition in the complex rehab market. While many providers may have been prepared for the ATS/ATP requirement, many more are still struggling for their certification, and even more are operating without an ATS/ATP on staff and have no intention of seeking certification. This creates opportunity for increased business to the top providers and new businesses set in place with adherence to the new certification requirements.
Providers must keep in mind the importance of seeking ATS/ATP certification. Again, professionals involved in the provision of AT services, specifically those addressing seating and mobility needs, can best serve their clients by having a working knowledge of the available options. Earning a RESNA credential enhances credibility to not only the provider, but to the industry as a whole.
We continue to support the RESNA ATS/ATP requirement, and providers who seek to continue their educational endeavors by receiving their certification. We are proud to be a part of strengthening the industry, extending educational support to our trusted providers, and ensuring safety and accountability for consumers. For more information on Pride's 2008 Seminar Tours and the RESNA prep courses offered, go to www.pridemobility.com.
Cody Verrett, ATS, is national sales director, Quantum Rehab, Exeter, Pa. Dan Fedor is general manager of education and compliance, Pride Mobility Products Corp, Exeter, Pa.