1. Fit and Proper Persons - Rule 1 is designed to ensure that DMEs and their key staff are ‘fit and proper’ people who are experienced, competent and qualified to offer services to, and interact with, unrepresented claimants. Do you agree with this rule and is it sufficient for this purpose or should there be other requirements considered?
2. Audit and Accreditation - Rule 2 requires DMEs to complete both a face to face audit interview with the MedCo Audit Team and the new Accreditation Module on dealing with unrepresented claimants. Do you agree that this rule is sufficient for the purpose of testing a DME’s capacity to provide these reports or should there be another way for DMEs to demonstrate that they can provide an acceptable level of service to unrepresented claimants?
3. Accreditation Training Module - MedCo is currently developing the new Accreditation Module for DMEs which will reflect the requirements included in these Rules. Are there any specific points or issues that you think MedCo should consider including in this new module?
4. Data Protection - Rule 3 relates to the responsibilities a DME has to comply with data protection legislation, including the recently introduced General Data Protection Regulation requirements. Would further explanatory material and/or links to information about data protection be helpful?
5. Interactions with Unrepresented Claimants - Rule 4 is drafted to provide reassurance that the DME selected by an unrepresented claimant (including vulnerable claimants), has effective, well-run systems, with sufficient experience and customer focussed processes to handle their requirements with courtesy, tact and sensitivity. Do you agree that this rule is sufficient for this purpose or should there be additional requirements?
6. Resources and Delivery - Rule 5 tests a DMEs back office capacity and ensures that they have sufficient resources, processes and customer service systems to interact with, and deliver an effective service to, unrepresented claimants. Do you agree that this rule is sufficient for the purpose of testing a DME’s systems or should there be another way for DMEs to demonstrate that they can provide an acceptable level of service to unrepresented claimants?
7. Provision of Information - The purpose of Rule 6 is to ensure that DMEs understand their responsibility to clearly explain the medical reporting process to unrepresented claimants, who may have little or no knowledge of what is expected of them. Do you agree that this rule is sufficient for this purpose or is there an alternative way for DMEs to demonstrate their compliance with this responsibility?
8. Opting-in - Having considered the attached new rules, do you intend to opt-in and be audited by MedCo to provide medical reports for unrepresented claimants?
9. General Comments - Having considered the draft rules do you have any additional comments/suggestions in relation to these rules that are not already covered by the questions above?