Comments on a Proposed LMRP: Response
Empire Medical / New York

This response to SVT's comments on a proposed LMRP shows how your comments can make a difference

August 29, 2001

George Berdejo
Society of Vascular Technology
4601 Presidents Drive, Suite 260
Lanham, MD 20706-4831

Dear Mr. Berdejo:
I am responding to your letter of July 23, 2001, regarding credentialing for providers of noninvasive vascular testing.

Thank you for your suggestions and literature on the scope of practice for diagnostic ultrasound professionals. However, as a Part B Carrier, our focus is not the credentialing or the scope of practice of approved practitioners. The Non-Invasive Diagnostic Vascular Testing policy has the unique distinction of having language on credentials, because there was a national concern on the quality of work in some of the old "physiological laboratories," at the time the policy was drafted.

Your comments seem to suggest that we require the credentialing of physicians. It is clearly not the responsibility of the Carrier to define qualifications of physicians. Scope of practice issues are more appropriately addressed by the State Education Department, in concert with professional organizations which issue competence criteria.
Within the Medicare arena, quality issues should be discussed with the Office of Clinical Standards and Quality (OCSQ), which is available on CMS's website, www.hcfa.gov.

I thank you for your compliments, and applaud you for your efforts.

Sincerely,
Norbert W. Rainford, M.D
Carrier Medical Director

EMPIRE MEDICARE SERVICES
Yorktown Heights, NY