Noridian training requirement

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onewithpain

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Noridian has a new LCD L33842 for facet injections. Most of it is the same as previous LCDs, but they have added;

Provider Qualifications
Provider Qualifications’ requirements must be met. Patient safety and quality of care mandate that healthcare professionals who perform Facet Joint Injections, Medial Branch Blocks, and Facet Joint Radiofrequency Neurotomy are appropriately experienced and/or trained to provide and manage the services. The CMS Manual System, Pub. 100-8, Program Integrity Manual, Chapter 13, Section 5.1 (http://www.cms.hhs.gov/manuals/downloads/pim83c13.pdf) underscores this point and states that "reasonable and necessary" services must be "ordered and/or furnished by qualified personnel." Services will be considered medically reasonable and necessary only if performed by appropriately experienced and/or formally trained providers.

The following training requirement applies only to those providers who have not provided these specific interventional pain management services on a regular basis (at least two times per month) during the ten years prior to the effective date of this LCD as may be established by claims billings. A basic requirement of payment is training and/or credentialing by a formal residency/fellowship program and/or other training program that is accredited by a nationally-recognized body and whose core curriculum includes the performance and management of the procedures addressed in this policy. Recognized accrediting bodies include only those whose program accreditation gains the trainee eligibility to sit for a healthcare-related licensing exam or licensing itself, which in turn allows the licensee to perform these procedures. At a minimum, training must cover and develop an understanding of anatomy and drug pharmacodynamics and kinetics, the technical performance of the procedure(s) and utilization of the required associated imaging modalities, and the diagnosis and management of potential complications from the intervention.

The following credentialing requirement applies to all providers of the services addressed in this policy. If the practitioner works in a hospital facility at any time and/or is credentialed by a hospital for any procedure, the practitioner must be credentialed to perform the same procedure in the outpatient setting.

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Correct me if I'm wrong, but this seems like a good thing, no? Appears to allow anyone who is trained, either in residency or fellowship, to do the procedures, and limits the PCP with a weekend course who wants to start doing them.
 
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agreed, just wish it specifically stated PHYSICIANS only
 
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I think that they had good intentions but were afraid to step on any toes. The requirement states that the training is part of the program's "core curriculum". I don't know too many residency programs where it is part of the core, but many that make it available as an elective. I know pain fellowship trained docs that say that they didn't get to perform MBB/RFA during fellowship, and the ACGME requirement for a pain fellowship states that the fellow must be involved in 10 cases treated with RFA. Could be eval and follow-up and not performance. And expect the nurse anesthetists and PAs to read this and make sure that their program includes it as a core and requirement for graduation and will then will cover it on an exam. The "grandfather clause" is a little weak. When I am ready to have it done again I will be looking for someone who does it more often than twice a month.
 
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