Q1. Can a form that is developed by an entity other than the supplier (e.g., the Power Mobility Device [PMD] evaluation forms that have been developed by the Texas Academy of Family Practitioners) and that is completed and signed by the physician and included in the patient's chart be considered sufficient documentation of the required face-to-face examination for PMDs?
A1. No. As stated in the Documentation Requirements section of the PMD Local Coverage Determination (LCD), physicians must document the face-to-face examination "in a detailed narrative note in their charts in the format that they use for other entries." Forms that are developed by other entities including but not limited to a supplier or professional association do not meet this requirement. Therefore, they are not sufficient by themselves to document that coverage criteria have been met. If a form is used, there must be documentation in the patient's medical record that corroborates the information on the form and verifies that coverage criteria have been met.
Q2. A supplier pays a physical therapist (PT) or occupational therapist (OT) to do wheelchair evaluations of non-Medicare patients (e.g., Medicaid only, commercial insurance). The PT or OT performs an evaluation on a Medicare patient and the supplier does not pay the PT/OT for that evaluation. Does Medicare consider that therapist to have a "financial relationship" with the supplier in the context of the Power Mobility Devices policy?
A2. Yes. In the situation that is described, the PT/OT is considered to have a financial relationship with the supplier. Therefore, even though the supplier does not pay the therapist for the evaluation of the Medicare patient, the evaluation of that patient cannot be considered part of the required face-to-face examination for all PMDs or the required specialty evaluation for rehab PMDs (Group 2 single and multiple power options power wheelchairs [PWCs], all Group 3 and Group 4 PWCs, and push-rim activated power assist devices for manual wheelchairs).
Q3. Can a physical therapy assistant (PTA) or an occupational therapy assistant (OTA) who is RESNA-certified as an Assistive Technology Practitioner (ATP) provide the specialty evaluation that is required for rehab PMDs that are provided on or after April 1, 2008?
A3. No. As with all professional services, the evaluation must be within the scope of practice of the health care provider as defined by state professional practice laws. Independent evaluations are not within the scope of practice of PTAs and OTAs.