In the draft Supplier Standards, CMS is proposing that a RESNA certified ATS be employed FULL-TIME by the supplier. Will the LCD be in conflict with proposed standards?
No, there would be no conflict between the proposed supplier standards and the DME MAC policy. The proposed supplier standards specify that the supplier must employ a full time ATS, but do not require that that individual have direct, in-person involvement with each patient. If that person did have direct involvement, that would satisfy the requirements of the DME MAC LCD. However, if the supplier wanted to hire additional part-time or contracted staff, that would meet the requirements of the LCD.
