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An Inherent Conflict of Interest—ATP Scribing for LCMP

Monday, November 18, 2019 @ 10:11 AM  posted by jbuytaert

Courtesy of Dan Fedor; U S Rehab

Several months ago I wrote an article titled “The ATP Dilemma” regarding an ATP scribing for an LCMP during the wheelchair (specialty) evaluation. At the time of the article, there were pieces of the puzzle where one could conclude that this is an unacceptable practice for several reasons as noted in the article. However, due to the lack of direct confirmation of the information available, some concluded that this practice was acceptable. Therefore, a pointed question was submitted to the DME MACs (both Noridian and CGS) in hopes of obtaining a clear answer regarding this practice. The DME MACs responded to the question with a concise, written answer during the quarterly Medicare Council meeting which was held on Nov. 12 and 13 in Nashville. The answer from Medicare confirms that this practice is not acceptable as there is an inherent conflict of interest since the supplier and LMCP can’t have any financial relationship, and by scribing for the LCMP, this is providing something of value (in kind) which violates the LCD. This can also lead to a possible Anti-Kickback violation.

Here is the exact question submitted to the DME MACs and their joint response:

Q: Is it acceptable for the supplier’s employed ATP to act as a scribe for the LCMP during the specialty evaluation?

DME MAC Response: This is not an acceptable practice. For the LCDs with LCMP evaluation requirements (power mobility devices, manual wheelchairs, wheelchair options/accessories and wheelchair seating), each profession has a separate and distinct role in the process to document the medical necessity of the item to be ordered. Each LCD clearly states the role and function of each professional evaluating the beneficiary. The LCDs specifically indicate that the “licensed certified medical professional,” such as a PT or OT, or a practitioner who has specific training and experience in rehabilitation wheelchair evaluations and that documents the need for the device in the beneficiary’s home. In addition, the LCDs indicate that there should be no financial relationship between the supplier and the LCMP. The ATP is hired by the supplier. If the ATP is scribing for the physical therapist, there is an inherent conflict of interest. Moreover, by serving as a scribe, the ATP makes the therapist more “efficient” by saving time, thus allowing them to see more patients, what is often described as “in kind” assistance. The requester may wish to seek an advisory opinion from the Office of Inspector General (OIG) to confirm.

End of DME MAC Response

Since it is now directly confirmed from all four DME MACs that having the ATP scribe for the LCMP during the specialty evaluation is not an acceptable practice, suppliers must be prepared to help educate LCMPs about the documentation requirements for complex rehab wheelchairs and accessories so they can efficiently prepare a comprehensive specialty evaluation with the necessary content for qualified patients to receive the ordered equipment in a timely manner.

It is a challenge to educate LCMPs on these requirements with consideration of their internal productivity requirements to see patients. However, a small investment of their time will yield ongoing results that will enable them to efficiently and effectively write a detailed specialty evaluation that addresses the LCD requirements. U.S Rehab is here to help with this education with materials, as well as a two-hour CEU course titled, “Documentation LIFE Preserver,” which is geared toward educating the LCMP with key points that must be addressed in their specialty evaluation. Please contact me directly at or 570-499-8459 about more details on offering this course in your area.

Dan Fedor

O: 844-794-8459
C: 570-499-8459

Thursday, October 24, 2019 @ 09:10 AM  posted by jbuytaert

Protecting Home Oxygen Medical Equipment Act of 2019

Monday, October 21, 2019 @ 12:10 PM  posted by jbuytaert

Wednesday, October 9, 2019 @ 12:10 PM  posted by jbuytaert


Tuesday, August 20, 2019 @ 08:08 AM  posted by jbuytaert

1. Be Prepared: Pack ostomy supplies in at least two places – carry-on and checked luggage. Take extra supplies in case you are stranded where supplies may not be available. For domestic flights, scissors are allowed in your carry-on luggage as long as the cutting edge is no longer than 4 inches (2.4 inches within Canada, check other foreign nation rules). Consider having pre-cut pouches for convenience and international travel. And of course empty your pouch before arriving for a trip. Be aware that the 3-1-1 Liquids Rule (also see TSA Video) requires that items classified as liquid, gel, aerosol, cream or paste must be carried in containers no larger than 100 mL (3.4 ounces). If your medical condition requires larger quantities and must be carried on board the plane they are allowable, but must be declared at the security checkpoint and require additional screening.

2. Request Passenger Support: Travelers with disabilities and those with medical conditions such as an ostomy who have concerns about airport screening should contact TSA Cares at least 72 hours before travel: toll-free at (855) 787-2227 (Federal Relay 711) or email TSA Cares agents provide callers with information about what to expect during screening so that travelers may better prepare. They can also provide a flight itinerary and will coordinate assistance available from a Passenger Support Specialist (PSS) and/or customer service manager at the airport. Airports differ on the level of assistance offered.

3. Get a Notification Card: Download our printable travel communication card. This is NOT a special security pass but it is a way to communicate discreetly to agents that you have an ostomy. You can also show a note from your physician explaining any of your medical conditions.

4. Consider TSA Pre-Check: You may find shorter lines and wait times by enrolling (for a fee) in TSA Pre✓®. Passengers still undergo screening at the checkpoint, but they do not need to remove shoes, laptops, 3-1-1 liquids, belts, or light jackets during the screening process at participating airports. TSA Officers may still swab your hands for explosives or do a pat-down.

5. Arrive Early: All travelers should arrive at least two hours early for domestic and three hours early for international flights. Allow plenty of time to empty your pouch if needed to help ease the security screening process.

6. Communicate at the Start: At the beginning of the screening process inform the TSA officer that you have an ostomy pouch attached to your body and where it is located. You may provide the officer with the TSA notification card or other medical documentation to describe your condition. Read more