Comments on a Proposed LMRP
Rhode Island

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 the response to the letter to see how your comments can make an impact on LMRPs.

August 1, 2000

Parker Staples, MD
Medicare Contractor Medical Director
Medicare Department
Blue Cross Blue Shield of Rhode Island
444 Westminster Street
Providence RI 02903-3279
FAX: 401-459-1709

Dear Dr. Staples:

On behalf of the Society of Vascular Technology (SVT), we want to thank you for your consideration of our 12 July letter. We are aware that LMRPs are local and expressed our views on behalf of the members and others who practice vascular technology in Rhode Island. Through the past decade, SVT has been actively involved in communicating with the federal Health Care Financing Administration (HCFA), both in response to proposed rule making and in other venues. Increasingly, our members in various states are requesting our assistance in responding to LMRPs. We have always appreciated the ability to work with national and local Medicare program policy makers.

We particularly appreciate your explanation about the abusive practices in Rhode island regarding CPT codes 93875, 903886, and 93922 and also appreciate your clarification in the final policy.

Regarding credentialing, we take this opportunity to note that SVT and other organizations comprised of sonographers (the Society of Diagnostic Medical Sonographers [SDMS], the American Institute for Ultrasound in Medicine [AIUM], and the Canadian Society of Diagnostic Medical Sonographers [CSDMS]) recently approved a new "Scope of Practice for Diagnostic Ultrasound Professionals" (enclosed). This document discusses the nature of the work undertaken by ultrasound professionals providing technical component services. It specifically indicates that credentialing is a standard that should be obtained by ultrasound professionals. It also describes the important discretionary functions undertaken by ultrasound professionals and the need for ultrasound professionals to act with an important measure of independence. In addition, we enclose an updated list of those Medicare carriers and intermediaries requiring credentialing for personnel involved in the delivery of ultrasound services.

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

Very truly yours,

Anne Jones, BSN, RN, RVT, RDMS, FSVU Frank West, BSN, RN, RVT, FSVU
Chair, SVT Government Relations Committee SVT Regulatory Advisor

cc: SVT Board of Directors & Suzanne Stone, Esq., SVT Executive Director