CMS Pub. 100-08, ch. 11, § 11.2

Contractors shall consider various elements when planning their LPET budget. For

example, contractors shall explain how they plan to allocate provider educational

activities between LPET and PCOM. The LPET subjects include medical review

findings, and education on LCDs as identified through the PCA process. PCOM subjects

include issues of national scope or impact. While there are fundamental differences

between the LPET and PCOM programs, there may be circumstances when it would be

feasible to provide educational events that encompass the scope of both of these

programs. For any function such as seminars, conventions, or conferences that address

LPET as well as PCOM subjects, the proportional share of the cost of that function to be

allocated to LPET, is equal to the percentage of time related to addressing LPET subject

matter, multiplied by the cost of the function. For example, the proportional share of the

cost of a seminar to be allocated to LPET, is equal to the percentage of the seminar

related to addressing LPET subjects, multiplied by the cost of the seminar (e.g., if it costs

$4,000 to arrange and conduct a seminar containing 75 percent MR and 25 percent

national coverage information, then the LPET cost would be $4,000 multiplied by 0.75 or

$3,000 and the remaining $1,000 would be charged to PCOM). However, if the intent of

the educational intervention is purely LPET, but PCOM issues arise; address the issues to

the extent possible, but charge the cost of the intervention to LPET. This methodology for

allocating costs also applies to other general, all-purpose provider education tools or

materials, such as regularly scheduled bulletins/newsletters. The costs for developing,

producing, and distributing bulletins, should be allocated proportionally according to the

percentage of the time spent on each subject in the bulletin between LPET and PCOM.

Each contractor will be given a specified maximum budget for LPET activities.

Contractors shall identify the appropriate budget and workload for each activity code

within the constraints of their budgets. Contractors are not permitted to charge

providers/suppliers for planned educational activities and training materials. However,

contractors may assess fees of no more than the cost for educational activities delivered at

a non-Medicare contractor sponsored event, or when specifically requested by specialty

societies or associations. In addition, although contractors are mandated to supply

providers with a paper copy of their bulletin at no cost, contractors may assess a fee to

cover costs if the provider requests additional copies. All monies collected must be

reported as a credit in the applicable activity code and accompanied with a rationale for

charging the fee. The fees must be fair and reasonable. Revenues collected from

discretionary activities must be used only to cover the cost of these activities and may not

be used to supplement other contractor activities.