I would like to comment on the proposed standard that DMEPOS providers not
contract with licensed personnel, ie. Repiratory Therapsit. That these licensed
professional now should be staff of the DMEPOS not on a 1099 basis.
This is a proposal that seems to be proposed based on the fact that CMS feels
that if the licensed professional is part of the staff of the DMEPOS supplier, then
the supplier is held more resposnible for the work of the licensed person.
Whether the licensed person is part of the staff or not, the work of this person is
preferenced by the fact that they do have a license. The state from which the
license was issued is reponsible for certifiying that the person is knowledgeable in
his or her field. Perhaps an alternative would be to require additional insurance by
the supplier to cover the licensed person.
As it stands, a proposal such as this will hurt small businesses. These
licensed professionals are "professionals" that require professional salaries,
which may cause a financial hardship on a small business. The
small provider may not do a large annual amount of business in the respiratory
area; thus, the licensed professional is used on a 1099 basis. Perhaps an
alternative would be to require that the licensed person be a staff member based
on a dollar amount. For example, if the supplier reaches $500,000 annually in
respiratory reimbursement from medicare, then it would be necessary to have the
licensed professional as part of the DMEPOS staff.
Anonymous-CA
This is comment on Proposed Rule
Medicare Program: Additional Durable Medical Equipment, Prosthetics, Orthotics, and Supplies Supplier Enrollment Safeguards; Establishment
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