Monday, June 23, 2008

POST #5: Responses to Comments posted 6/20 - 6/22

Q: One cannot stand in the way of evolution but the timing of its presentation in this time of recession and financial crises with an aging work force adds to stress and pressure. I noticed the presentation of electronic test taking and even that increased anxiety levels. (anonymous)

A: We realize that there are major changes in the industry with competitive bidding as well as other policy changes. The PSB is looking at our entire process to move forward in a logical, defensible direction. Those already certified will not be required to retake the test and will be transferred to the new certification at no cost.

The plans for computer-based testing are for the benefit of candidates also. Greater access to testing centers locally, availability of an exam on an as-needed basis, and results given at the end of the testing rather than a wait time of a few weeks are the advantages.

Q: Do not group the ATS and ATP into one category because our roles and educational background are not the same and that delineation was made for a reason. I do agree on the aspect of having specialty certifications as a way of showing that we are more knowledgeable in one or more areas. (anonymous)

A: We agree that the roles are different, and the educational background may be different, but there is a common defined scope of knowledge for both. Furthermore individuals change roles in the service delivery process throughout their careers. When certification makes the delineation between who does what, it is crossing the line into regulatory issues. The goal is to test competency in a knowledge base. The educational background, practice setting, employer requirements, funding source policy, and regulatory bodies will decide who will be paid for what service.

Q: My concern is that vendors will take on chairs that they cannot handle and confuse patients with their ATP certification. Patients may think they are specialists, when in fact they are not required to have the background that ATPs have to have to sit for the exam (anonymous).

A: The eligibility requirements between the current ATP and ATS differ in that a supplier may have a high school equivalency or higher, and any college degree is acceptable for either ATS or ATP given the right number of years of relevant work experience. The ATP that is a licensed therapist certainly has other qualifications and skills. We are not trying to equate an ATS to become what is currently thought of as an ATP. Perhaps this is also a good argument to call the certification something entirely different. What will decide roles and responsibilities is not the certification but rather the employer, funding sources, and regulatory bodies.

We have equal concern with anyone supplying AT equipment or services beyond their scope of competence. The RESNA Standards of Practice and Code of Ethics specifically outline the guidelines for ethical practice. Individual certified by RESNA agree to abide by these standards. The RESNA PSB has an established Complaints Review Committee to handle violations of these standards. It is the responsibility of all to report a known violation through the established Complaints Procedure. The PSB can not act on a breach of standards or ethical practice if no complaint is filed.

Q: I was pleased to see this effort and will support further credentialing into specialties (James Noland)

A: Thank you. As we move forward, we will continue to solicit input to guide the development of any advanced certifications or educational certificate programs. The development of future programs will be dictated by feasibility based on the level of interest, demand and financial resources.

Q: Does this mean RTSs not yet certified will have to take more than one exam? What type of "specialty certifications" do you envision?

And if the new baseline certification is called something other than ATS or ATP will RESNA work that out with Medicare since they require RTSs to be an ATS or ATP currently to provide equipment for Medicare? And will persons already certified ATS or ATP be grandfathered in with the new credential (anonymous)?

A: The RTS who is not yet certified would still take the one basic AT certification exam, whatever the new name. Right now, a seating and mobility specialty certification is planned to honor the commitment made many years ago to those wishing to further distinguish their AT specialty knowledge. Any future specialty certifications or educational certificate programs will be pursued to meet the need and demand. Alternate formats from a formal exam can be considered for these, as mentioned in the earlier post.

RESNA has already spoken with the DME MAC Medical directors regarding this proposed change, and they indicated that changing to a single certification would be in line with their intent also. RESNA will continue to maintain dialogue with CMS as well as many other stakeholders (Medicaid, state policy makers, etc.) to make sure any name changes are recognized and reflected in existing policy. Furthermore the PSB has engaged consultants to assist with the branding and promotion of the RESNA certifications. The goal is to increase the visibility and knowledge of the RESNA certification program and value of certification in the eyes of employers, funding sources, and the general public.

Q: I am wondering if this change will undermine the ATP that we already have. Specialty certifications often do. I am also not sure what weight this will really hold among the respective professions. I do have concerns with this (Gina Mirigliani, OTD, OTR/L, ATP).

A: Your ATP will still indicate that you have demonstrated competency in the specialty area of AT, but it will not imply what the certification enables you to do, as that is outside of the scope or intent of certification programs. Your other credentials (i.e. OT, PT, SLP, engineering, etc.) will indicate what you are able to do and who will pay you for your services. We have also contacted a number of stakeholders, such as CMS, NRRTS, AOTA, APTA, and ASHA to notify them of our proposed changes, to seek their input, and to involve them as we move forward with specialty certifications. We have had early indications of interest. We will continue the dialogues and work together where it is logical and where there is mutual interest.

Friday, June 20, 2008

Post #4: Responses to comments posted 6/19/08

Q: RESNA needs to monitor its website much better. I would refer people to the website and the directory was down. Information about what to expect from individuals certified by RESNA was not clear. (anonymous)

A: RESNA launched its new website on June 15, 2008. The bugs are still to be shaken out. The new website will allow better access and resources for members and certificants, and the capability for individuals to edit and update information will be added to ensure that the website is current. Also, there will be automatic notifications for recertification, announcements, links for continuing education opportunities, and more. The directory of ATPs and ATSs also now show an “effective until” date for each certificant.

Q: Seating and mobility is not always wheeled mobility or wheelchair seating. There are numerous seating systems in schools. The certification is very confining. It has taken so long to gain recognition of the ATP that to change it is unbelievable. There is scant respect for the ATP in my job by my employer and now to change it seems to dilute its worth as a level of excellence. Too bad RESNA didn't campaign for more ATP presence in government issues. I have been urging APTA to recognize AT as a skill in physical therapy and now RESNA does this... (anonymous)

A: The ATP and ATS always have been general assistive technology certifications which test content in many areas of AT practice, including seating and wheeled mobility, seating and positioning. RESNA is making a focused effort to increase the visibility and value of your current (and a new single certification) and has employed a marketing firm to develop materials to assist with branding and promotion of the RESNA trademark designations. Any changes to the certification program would still recognize and test basic core knowledge in AT. The RESNA PSB has reached out to a number of stakeholders, including CMS, APTA, NRRTS, AOTA, ASHA, and others to invite them to the table as we develop a new basic certification and a multi-disciplinary specialty certification in Seating and Mobility.

Q: I believe that you have made an error in assumption. Until just a few years ago, the licensure of occupational therapists was made by their own professional organization and not by any governmental body. They had to lobby hard and campaign for curriculum changes to gain licensure in California. The governmental boards did not consider them a medical professional because of the lack of medical and science curriculum of their schools.

A: You are correct. The field of AT is young, and one of the obstacles we are encountering is that AT is not significantly embedded in most curriculums. There is a level of rigor required and distinct body of knowledge to define before entertaining licensure for a profession. This has been successfully accomplished by the orthotics and prosthetics profession. When licensure is not a requirement, certification offers credibility and value, and that is the intent of the RESNA certifications in AT. There are many ATPs who practice within the field that are not licensed therapists but who do specialize in the area of AT. They work in many different practice settings, including the education system, vocational rehabilitation, independent living centers and workplace accommodation. A certification in AT has helped them to differentiate their specialty knowledge.

Q: The original vision of RESNA, way back when we began discussing the certification process 13 or 14 years ago was to eventually develop specialty exams for individuals who specialize in a particular area of practice when the time was right. The time became “right” when the LCD required that an ATS (or an ATP working for a supplier) be involved in the equipment selection process for certain power mobility devices. We expect this language to be included in a revision to the Manual Wheelchair policy as well as the Wheelchair Options and Accessories policy and the Wheelchair Seating policy in the future. The ATP language was removed from the policy due to strong lobbying efforts of the APTA and the AOTA and the realization by the CMS medical directors that an ATP certification was a generalist certification, not a specialty certification in seating and wheeled mobility. In fact, they questioned why there were two generalist certifications, which they saw as confusing and possibly misleading. Hence the consolidation – I think this is a move in the right direction and will clear up a lot of confusion related to roles and who can do what (anonymous).

A: The motivation for the PSB was to remove confusion caused when certification was tied to an individual’s role in the AT service delivery process. We are committed to increase the value of the basic level certification and have therefore engaged the services of a marketing firm to help increase the visibility and name recognition of the RESNA certifications. In addition, the reason for consolidation to a single certification is to make it stronger and more defensible, and to conform to accreditation standards for certification programs. For those specialty areas where it makes sense and there is demand and value to advanced certification, the PSB and Board of Directors of RESNA are committed to developing these certifications. The first specialty to be developed is in Seating and Mobility, with projected date of July 1 2009 for implementation.

Q: I believe that adding on more advanced certifications is ludacrist (sic). As a practicing occupational therapist for 10 years, I was happy to get my ATP. I do not think that I need an advanced certificate in seating and mobility to prove that I know my job. I went to school for 5 years and learned about seating and mobility. It is a core concept taught to occupational therapists. I think that the designations should remain the same and that RESNA should not create advanced certifications. I agree with the other bloggers who think that enough is enough. It seems that it has become more about money than the profession of AT. (anonymous)

A: An advanced certification is not necessary for everyone. The reason the basic certification exists is that it will meet the diverse needs of many practicing in different areas and settings in AT. Specialty certification comes at a significant expense to RESNA, without the volume of individuals that the basic certification provides. Therefore, it demonstrates a commitment of the RESNA Board of Directors to deliver on the initial promise identified 13 years ago to those desiring further specialization. It will not be appropriate or necessary for every area of AT practice and will be driven by demand. Seating and wheeled mobility is the first area to be developed based on identified need and stakeholder demand. Also there are different venues or platforms which can be used to demonstrate specialty knowledge. For example, certificate programs designed to provide concentrated advanced training in a specific content area. Additional exams are not always the best or most appropriate option.

Q: I concur with Michelle Lange. I would like to see the potential specialty certification as an advanced practitioner in an area of practice, such as seating/mobility, AAC, computer access, etc. I am not a proponent of lumping the group of vendors with providers unless the vendor has passed the same exam as the provider demonstrating enhanced knowledge at the practitioner level. In addition, if the knowledge base of the two exams is so close, then maybe the practitioner exam needs to be brought up to a higher level (Matthew Press)

A: Essentially, the current test blueprint for both ATP and ATS exams are identical. The job analysis shows no distinction in basic AT knowledge between the two designations. Currently, 150 of the 200 items on both exams are common. Therefore, having one exam will allow us to test in greater depth AT application with more “real estate” for testing (50 items). The ATP and ATS exams were not designed to be hierarchical. It is the combination of educational training, on-the-job experience and passing the exam that demonstrates the higher level of knowledge.

Q: You make the assumption that all ATPs are therapists and subject to licensure. This is incorrect. Most of the Rehabilitation Technologists I know are not therapists. To have a single certification that covers both vendors and practitioners blurs the line between people the consumer can trust to have only their best interests in mind and people who have interest in influencing the consumer to purchase a certain brand of product. This negates the value of the certification as far as I am concerned and will make me think twice about renewing if the change is made. It costs too much to maintain the ATP certification for me not to feel that it gives my consumers reason to trust that I am not ONLY competent but ethically committed to finding the best product to suit their needs regardless of brand (Susan Levi).

A: We have many ATPs that are not therapists and are not licensed. When you pass either exam, you also commit to abiding by the RESNA Code of Ethics and Standards of Practice. The PSB has a process to handle complaints and take action against those who violate these standards, ranging from warning to revocation. It is the collective responsibility of the industry to raise the bar and to identify individuals who are not practicing according to the RESNA Code of Ethics and Standards of Practice. Unless a complaint is formally filed the PSB can take no action. Once a complaint is filed the Complaints Review Committee within the PSB has the responsibility to review, investigate and adjudicate as deemed necessary.

It is the mission of RESNA certification program to identify individuals who have demonstrated competency in an identified knowledge base. Certification is not to imply permission to perform a certain role. People change roles, and the certification then is misleading. The PSB explored the feasibility of converting certifications when an individuals’ role changes. We found that that was not a defensible method since there was not a bright line distinction between basic core AT knowledge for the ATP and ATS. The job analysis resulted in one common test blueprint. Although we find that different members of the AT team contribute different background and skills, the core AT foundation knowledge is the same. Without an identifiable difference, there is no defensible method for testing or converting a certification, and it becomes just a title.

Q: The problem with one exam is how to make a meaningful exam that someone with a GED or doctorate has the same core, entry level knowledge. This also does not address the problem I had in that the current ATP exam had very little in my area of physical therapy, seating & positioning. There was so much on speech & computer that passing it does little to ensure that a person can correctly determine wheelchair needs. I can see where advanced certification could come in here, but it does seem like a revenue generator. I'm having a hard enough time now wondering why I need the certification since Medicare withdrew the requirement for PTs. How does this fit in for the future since Medicare has continued to require certification for vendors? As for being designated CAT-please tell me you're kidding (Lynn Kelly PT, DPT, ATP).

A: The ATP and ATS certifications were designed to demonstrate basic core AT knowledge including but not limited to functional implications of disabling conditions, application of AT, legislation and funding, standards and ethics. Neither exam was designed specific to seating and wheeled mobility. Competency in basic AT knowledge enables AT professionals with different educational and practice backgrounds to communicate with persons with a disability and with each other, using a common language and understanding of disability and technology. Regardless of the area of practice, each individual involved in the recommendation of any assistive technology needs to be aware of other AT needs that impact upon the choices offered, and recognize when to refer elsewhere.

An advanced certification in the area of seating and mobility will enable those interested in distinguishing their knowledge in this content area. As mentioned earlier, specialty certification comes at a significant expense to RESNA, without the volume of individuals that the basic certification provides.

In the current Local Coverage Policy (LCD) for Power Mobility Devices, CMS has specified that the beneficiary must be evaluated by a licensed certified medical professional (LCMP) independent of the sale of the device. CMS already made a change to allow the supplier directly involved with the consumer in recommending the wheelchair to be either ATP or ATS-certified. In our discussions with the DME MAC Medical Directors for CMS, they have indicated that this change and the development of an advanced certification specific to seating and wheeled mobility would be in line with their own future direction.

The name of the new certification has not been finalized. There are several options on the table and the PSB is compiling all input for consideration.

Thursday, June 19, 2008

POST#3: Responses to comments posted June 18

Q: Thanks for the information. There is much to digest here (anonymous).

A: You are correct. We are taking time to respond specifically to the comments and will publish comments and responses daily or twice a day so that we can be responsive to all input and views to guide our process.

Q: I think this will further confuse people - make everyone with an AT certification look like a vendor - therefore lumping in the sales staff with the licensed therapist who are evaluating and providing therapy services NOT selling equipment (anonymous).

A: RESNA’s certification should not define the person’s role but rather his/her knowledge of assistive technology. The intent of the single certification is to remove the implication of the role. Roles are defined by other credentials, i.e. licensure. The therapist will always have their OT or PT designation and their licensure that gives them the right to practice.

Q: So, let me get this straight, to keep doing what I am doing now as an ATS, I will have to "become certified" in the areas of seating, aug comm, mobility, etc individually (anonymous)?

A: Someone who has earned their ATP or ATS certification would still be RESNA-certified, no matter what the new designation is called. This designation would still be valid and recognized as it is now, with plans to increase its visibility and therefore its value to you. It is still the basic certification that identified core competency in the AT field, and we expect that this certification will still hold value in many areas of practice without further advanced certification. While the present and future basic certifications identify core competency, it does not address a person’s expertise in areas such as seating and mobility. The specialty certification is designed to recognize advanced knowledge and expertise in a particular area, and would only be developed for an area of practice where there may be a desire for individual to further distinguish themselves with demonstration of a deeper knowledge. Arguments against requiring the ATP by CMS for professionals performing seating and mobility evaluations involved the fact that the ATP did not acknowledge a specific expertise in these types of evaluations, only a basic knowledge of AT. The specialty certification will address this issue and may ultimately be recognized by CMS.

Q: I like the idea of a single credential. It has been very confusing for me, in switching roles, to call myself an ATP, work as a supplier, sign an attestation stating I don't receive financial benefit from a sale when renewing. Would I now have to resit for the exam as an ATS? Also, if I choose to return to a clinical setting, then I would sit again? Make the certification "portable" - you don't lose your designation just because you don't practice in other fields (anonymous).

A: This was precisely the confusion RESNA is trying to alleviate. Certification is intended to recognize individuals who demonstrate competency, while licensure determines what they are/are not alowed to do. One certification tests the common knowledge that each individual needs to speak a common language, understand the various needs ot te client served, and to "do no harm".

Q: I support the idea of advanced certifications, but would like to see the current ATS and ATP certifications remain the same. These could each be a prerequisite for the advanced certifications. Even though the two groups share quite a bit on content on the exam, different skills are required as a practitioner and as a supplier (Michelle Lange, OTR, ABDA, ATP).

A: We agree that the though the skills of a supplier are different from a practitioner, the core AT knowledge base is the same. Skills are developed from formal and informal training, and often on the job. The RESNA certification tests ONLY knowledge. There is no test or objective measure of “skill” such as a practicum, or portfolio. RESNA certificants are not tested in their patient handling skills, treatment, use of tools, knowledge about latest products, and other areas.

The basic certification will, indeed, be a prerequisite for any advanced certification.

Q: I feel that what RESNA needs to do is enforce their current code of ethics, so when a violation of those are reported to RESNA say in February 2008 it doesn’t go on 4 months and counting to be reviewed by the PSB (professional standards board). To date this individual has been found guilty by a jury in February 2008 of violation of The Uniform Trade Secrets Act; 59.1-336 and is still an ATS and working. If RESNA wants a professional ethical team of certified individuals, then they need to support those that uphold patient privacy, maintain confidentially of privileged information, Engage in no conduct that constitutes a conflict of interest or that adversely reflects on the association and, more broadly, on professional practice, Hold paramount the welfare of persons served professionally, Comply with the laws and policies that guide professional practice, Issue public statements in an objective and truthful manner and Practice only in their area(s) of competence and maintain high standard (anonymous).

A: RESNA has established a Complaints Review Committee through the Professional Standards Board, to handle all adjudications. In the case mentioned above, the person in question has been informed of the decision to revoke certification and has a time in which to appeal. We too believe that the effectiveness of “policing” the certification and acting on violations is critical, especially as the visibility of the certification and its value increases and more violations are reported. RESNA is and has been taking steps to enforce a disciplinary action policy that is legally defensible. The proposed changes to the certification will make it much more legally defensible, thus insuring adjudications will be effective and much less prone to legal challenges.

Q: RESNA is on the right track do not be derailed by growth, government or bureaucrats. To add more requirements, certifications, etc. only places an unduly stress on the small businesses out there. Yes, I agree that RESNA should have certificates that are specialized in seating, progressive and non-progressive diseases and proper placement for AT, ROM deficits and compensation for and through AT placement….. however, these should be classes offered like the ones in Washington DC in June. If continuing education is the key, then offer it and we will come. Present the attendees after the 1 or 2 day class has ended with a certificate of completion. Stop mandating us to death. Me and the other 99.9% of ATS, ATP, RET are dedicated and committed to our patients and their well-being and that is what it’s about, the patient (anonymous).

A: Specialty certification, if it needs to exist in a particular area of practice, can be handled in many ways, like you just described. There is no need to always develop another exam to show advanced knowledge, and RESNA is planning more opportunities for relevant continuing education using online resources. Another possibility is the development of certification programs that offer advanced training rather than an exam. We would welcome your feedback as to development of courses like this to further train individuals as well as bring new members into the field.

Q: Would the new broad certification test be any more or less difficult than the current ATP or ATS exam (anonymous)?

A: The new test will essentially be equivalent to the current tests. Currently there are 150 of the 200 questions are common to both the ATS and ATP exams. The remaining 50 questions will be derived from the same knowledge base. The same content area would be covered and the exam is still intended as an basic level (with experience) certification in the broad field of AT.

Q:
Sounds like the bar is being lowered to accommodate those suppliers/sales reps who can't pass the original ATS exam (anonymous).

A: The bar will not be lowered. The exam outline and content will be the same. There will no longer be separate “supplier” questions, vs. “practitioner” questions. This allows RESNA to test the core knowledge base more thoroughly within the same testing “real estate”.

Q: If it aint' broke, don't fix it. What is wrong with the system we have now? I was proud to acheive the ATP certification. If it's so "entry level" then why have so many failed it? I think this is a "white wash" to dilute the pool (anonymous).

The primary problem with current system is that it is based on “roles.” Over the years, people working as an ATP have switched roles to work for suppliers; some ATSs have moved to the ATP side. They have been able to maintain their initial certification in the past regardless of this change in role, and many have renewed their certification multiple times already. When those changes occur, we do not have a defensible mechanism to convert people from one to the other, as the core knowledge on which they are tested is the same. A number of scenarios were considered by the PSB to address this problem. It was concluded the best approach was a common certification that tested basic AT knowledge.

The proposed exam will test the same knowledge base as the current ATP. Those who have had trouble passing the ATP or the ATS exam will not find the new exam any easier. It is important to note, the new certification exam does NOT lower the bar. No matter what a person’s background is, they will still be required to pass the exam in order to be certified.

The test is intended to draw a line between those who have demonstrated basic AT knowledge and those who have not. Having a single certification does not undermine the value of the current certification of ATP or ATS, which still demonstrate who has shown competency in the knowledge tested.

Q: Was the ATS/ATP system broken? Then why "fix" it? Oh yeah, more exams, more money...I get it now (anonymous).

A: The proposed certification does, indeed, fix a number of problems with the current program. (See response above)

There will be NO additional exams for those already certified. There will be NO additional costs to those already certified.

The new certification exam will replace the current ATP and ATS exams and will become available through computer-based testing, facilitating access for everyone around the country, and around the world. RESNA is planning to help increase the visibility and value of your current (and the new certification) – in most cases, this baseline will be all that is needed. Specialty certification will be developed only as the need and demand for it is present, and it is only to demonstrate advanced knowledge. This can be done in many ways besides an exam. For instance, it could be offered as specialty training or certificate programs, or other methods like a portfolio.

Q: I think this is a ploy to dilute the ATP Certification. I find it hard to believe enough ATS's have control over the PCB to force them to reduce ATP to equal ATS. In the mind of consumers, payors, and the medical profession they are not the same thing at all. Looking at only a few other professions it is clear that a more advanced level of practice is recognized. AS example, MT and MLT for medical technologist. I strongly believe this idea needs much for thought prior to it moving forward. I also think a change as large as this should go before the entire membership for vote (anonymous).

A: There is no “ploy” or sinister motive in proposing the new certification. The PSB (Professional Standards Board) and the RESNA Board of Directors (who have decided to pursue the new certification) have the best interests of RESNA certificants, members and consumers in mind.

The current ATP and ATS tests were not hierarchical. Because they were initially conceived with the idea that roles needed to be defined, and time has shown us that there is blurring of these lines, and people change jobs, it no longer makes sense to tie certification to the role, but rather to it's original intent; to test core competency in the knowledge base.