The American Association for Homecare submitted comments to the Seat Elevation Systems as an Accessory to Power Wheelchairs (Group 3) Decision Memo and shared those comments with the industry.
CMS’s proposed NCD would cover power seat elevation equipment under Medicare for beneficiaries using Group 3 power wheelchairs for the first time. The proposed NCD was open for public comment until last Friday, March 17. The proposed NCD decision memorandum is available to review here.
More than 2,100 comments were submitted. For a deep dive into the issues covered in the public comments, click here.
AAHomecare’s comments supported the beneficiary and clinical communities, and urged CMS to finalize the National Coverage Determination with the following considerations included:
- Finalize the proposed Benefit Category Determination holding that power seat elevation systems are primarily medical in nature and are considered durable medical equipment under the Medicare benefit, and finalize the proposed coverage determination holding that these systems are reasonable and necessary for Medicare beneficiaries who use Group 3 and above CRT power wheelchairs in order to perform transfers for the purpose of performing or participating in mobility-related activities of daily living (MRADLs).
- Include coverage for Medicare beneficiaries who need seat elevation to improve their reach and line of sight to support shoulder, upper spine, and neck integrity while performing or participating in MRADLs.
- Include coverage of seat elevation for Medicare beneficiaries who use Group 2 CRT power wheelchairs in the final NCD.
- Provide important clarifications to the proposed NCD, including further detail regarding “weight-bearing transfers,” beneficiaries using patient transfer devices, and the specific criteria for specialty evaluations.
AAHomecare made its full comments available as a downloadable PDF.
