Comments on a Proposed LMRP:
Empire Medical / New York

This letter can serve as a model on commenting on a local medical review policy (LMRP). Because all proposed LMRPs will vary to some extent, you will need to adopt this model to your specific situation.

Read Empire's response to this comment.

July 23, 2001

Norbert Rainford, MD
Empire Medical Services
2651 Strang Boulevard
Yorktown Height, NY 10598

Dear Dr. Rainford:

We thank you for the dedication and leadership you have demonstrated in serving the Medicare beneficiaries of New York State. We want you to know that we, too, are committed to serving Medicare beneficiaries. It is because of our shared commitment to serve these patients' best interests that we are writing to express our belief that the above named policy should be modified. We are eager to work with you to establish appropriate medical review policies and would be pleased to meet with you to discuss this further.

The Society of Vascular Technology (SVT), founded in 1977, is a professional society for vascular surgeons, nurses, and technologists, completely dedicated to the advancement of noninvasive vascular technology in the diagnosis of vascular disease. SVT is comprised of more than 4,000 members, including 1,000 physicians. The Society of Diagnostic Medical Sonography (SDMS), which represents sonographers practicing in all specialties of ultrasound, has a membership of 12,000. SDMS members are involved in the delivery of high-quality echocardiography, obstetrical, neurosonography, abdominal, ophthalmic, and vascular ultrasound services.

On behalf of the 15,000 members of both societies, we are writing to communicate concern with Contractor Policy Number VS001E03, in particular, credentialing. Because we believe very strongly that the accuracy of non-invasive vascular testing is substantially related to the qualifications of the person undertaking the technical component of the service, we urge that the LMRP require all practitioners providing non-invasive vascular testing be credentialed. In order to allow an appropriate transition period, we suggest a three-year period from the effective date in which non-credentialed personnel may perform services under the direct supervision of credentialed personnel. At this point, given the development of the credentialing mechanisms, the recent (and quite appropriate) attention focused on medical errors, and the disturbing evidence of sub-standard care provided by non-credentialed personnel, we believe very strongly that proof of a minimum level of competency is absolutely essential.

All the professional ultrasound associations have endorsed the "Scope of Practice for the Diagnostic Ultrasound Professional", which includes the standard
for ultrasound credentialing as those provided by organizations that meet the National Commission for Certifying Agencies (NCCA) Category "A" accreditation standards. This currently includes for vascular technology the Registered Vascular Technologist ("RVT") credential. In addition, our societies have recommended to other carriers inclusion of the Registered Vascular Specialist ("RVS") credential.

We note that examples of "appropriate personal certification" in this LMRP include the RVT (mistakenly abbreviated as the RCT) and the RVS (formerly called the RCVT), as well as, the credential offered by the ARRT. We believe that this credential should not be included as an appropriate certification for personnel performing vascular technology. The ARRT credential does not meet the parity standard for education, training, and testing requirements embraced by the professional ultrasound community. Additionally, the educational community serving the radiological sciences field does not support this exam; the professional association for radiologic educators, the Association of Educators in Radiological Sciences (AERS), opposes the ARRT exam. Finally, the ARRT exam is exclusionary. Only radiologic technologists are allowed to sit for the exam.

SVT has a formal process for review and evaluation of certification programs, which relies on the "SVT Guidelines for Evaluation of Credentialing for Vascular Technologists". SVT does not have any financial stake in any credentialing process and supports credentialing purely from a patient care perspective.

Thank you for the opportunity to communicate with you on this important policy. We are grateful for your leadership, commitment, and dedication.

Sincerely,

George Berdejo, BA, RVT
SVT Carrier Medical Director Network Representative

Christy Cornwell, LPN, RVT
SVT Carrier Medical Director Network Advisor