by Cheryl Nash


Recently a client alerted me to a Medicare audit they received. Aside from the usual pull list for medical records, an interesting additional request caught our attention. On this occasion Medicare also asked for “a copy of licenses and/or certifications for all personnel documenting in the beneficiary’s chart or performing services.”


While seeming to be a rather benign request, something that should be taken into consideration here is that Medicare has strict parameters on who can perform what. One particular service that sometimes misses the radar is Diagnostic Studies.


There are some very specific educational requirements that have to be met in order to be considered qualified to perform or interpret a vascular diagnostic study which Medicare has had published in their Local Coverage Determination’s for several years now. In brief, Medicare requires the individual performing studies to be able to show training and expertise in vascular studies either through an accredited specialty or sub specialty, hold a recognized certification in vascular studies, or be performed in an accredited facility.


This requirement affects almost all instances of care in a phlebology practice as virtually all services require some component of vascular ultrasound.  It would appear that Medicare is closely scrutinizing all aspects to the patient chart, including not just what was done and if the chart supports that care, but also who is performing the care.

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