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Here is what a WPS Medicare Representative advised me in 2010 when I asked the question about a Medical Assistant performing a physiologic test and the practitioner billing for the exam.

Dear Mr. Ross,

Thank you for the inquiry you sent to Wisconsin Physicians Service (WPS) Medicare regarding Local Coverage Determination (LCD) L28586 “Noninvasive Vascular Testing (N.I.V.T.).”

As you requested during our telephone conversation on June 17, 2010, I am responding in writing to your inquiry. I forwarded your question to a member of our Medical Policy professional staff for assistance with answering your question. The Medical Policy staff member provided the following response. For the sake of clarity, I am restating your question.

If a medical assistant or anyone else not meeting the qualifications of a certified vascular technician (VT) performs the technical component in the office setting of the Current Procedural Terminology (CPT) codes 93922, 93923, 93924, 93965, and the physician bills WPS Medicare, would this be considered a fraudulent claim?

Medicare would consider the above services as not medically necessary.  While we would not necessarily know on a prepayment basis that the service was being provided by an unqualified person, Medicare could look at this on a post-payment basis, and Medicare could ask the provider to refund the money he or she received. This could be done by the local carrier or the Recovery Audit Contractor (RAC). The whole purpose of requiring certification is that Medicare considers reimbursement for quality images that will contribute to a correct diagnosis and treatment of the patient.

You may access the above-referenced LCD on the following WPS Medicare Website:

http://www.wpsmedicare.com/part_b/policy/active/local/_files/l28586_cv033.pdf <http://www.wpsmedicare.com/part_b/policy/active/local/_files/l28586_cv033.pdf>

I hope this information is helpful. If you need additional assistance from WPS Medicare regarding this matter, please include the reference number below in any correspondence. If immediate assistance is needed, you may reach our Provider Contact Center by calling 866-234-7331.

Sincerely,

Barbara Lawrenz
Provider Relations Research Specialist
WPS Medicare 
This information was sent on 6/17/10. I would suggest you contact your CMS representative and update the information if you are in questions. 

We have never allowed Medical Assistants to perform physiologic tests: 93922; 93923;93924;93965.

Sincerely,

Robert R. Ross, PA-C
Michigan

> On Nov 7, 2020, at 7:19 AM, Alessandro Nardone <[log in to unmask]> wrote:
> 
> And thank everyone for the feedback
> 
> On Fri, Nov 6, 2020 at 10:07 AM Alessandro Nardone <[log in to unmask] <mailto:[log in to unmask]>> wrote:
> Hi All
> 
> Does anyone have or know of any position papers on training MA’s or other non sonographer personnel on performing ABI studies? It would be Very helpful if you would let me know. I did read a position paper on training fellows and doctors early in education but not what I was looking for. 
> 
> Thank you
> Alessandro (Sandy) Nardone RVT, RVS
> Northwell Health Western Region
> 
> 
> 
> 
> 
> -- 
> Alessandro (Sandy) Nardone RVT,RVS, RCS
> Practice Coordinator Technical Imaging/Technical Director
> Northwell Physician Partners- Cardiology Western Region
> Cell: 516-382-1476
> 
> 
> 
> -- 
> Alessandro (Sandy) Nardone RVT,RVS, RCS
> Practice Coordinator Technical Imaging/Technical Director
> Northwell Physician Partners- Cardiology Western Region
> Cell: 516-382-1476
> 
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