CMS Opens NCD Reconsideration for Seat Elevation Systems

A public comment period is open until Sept. 14, and HME advocates are urging all members of the industry, and particularly CRT stakeholders, to submit. Notably, the reconsideration does not include power standing systems.

CMS has opened reconsideration of the Medicare National Coverage Determination (NCD) for seat elevation systems used with Group 3 power wheelchairs.

The reconsideration is accompanied by a public comment period that will be open until Sept. 14. Organizations such as the American Association for Homecare, the National Coalition for Assistive and Rehab Technology (NCART), and the Independence Through Enhancement of Medicare and Medicaid (ITEM) Coalition, are urging HME and particularly complex rehab technology (CRT) to join the public comment push.

Advocates can submit their comments on CMS’s site in reference to CAG-00461N.

To help providers prepare their comments, AAHomecare has built a Seat Elevation/Standing Systems NCD Reconsideration Central web page for messaging and resources.

Also, the ITEM Coalition has created to help mobility device users and the public advocate for coverage of the systems. Providers are encouraged to share the webpage with patients, clinicians, and other contacts to drive a strong response on this issue.

Long Time Coming

For many, opening reconsideration of the NCD is a long time coming. While elevation/standing technology has been around since at least 2015, Medicare has not funded these systems on the basis that it considers them “not primarily medical in nature.”

However, there are some private payer, state Medicaid programs, the VA, and other non-Medicare reimbursement sources that do fund power elevation because it helps mobility device users better engage with people, carry out daily tasks more safely and effectively, and prevents injuries related to craning their necks.

“Opening the coverage determination for power seat elevation is a very positive development for individuals with profound mobility challenges,” said Tom Ryan, AAHomecare president & CEO. “These systems have the capability to improve the health, independence, and quality of life for Medicare beneficiaries with severe disabilities.”

Not Far Enough

While the seat elevation NCD reconsideration is good news, it was hoped that the reconsideration would also include power standing systems, which it did not, much to the frustration of CRT advocates. Rather, CMS decided to delay that review until a later date.

“NCART is extremely disappointed with this decision since power standing systems were included as a connected benefit in the initial September 2020 request for coverage,” the association noted in a public statement. “We will be actively working with the ITEM Coalition and our Congressional supporters to push CMS to open the public comment period for this technology as soon as possible so that review can continue.”

The ITEM Coalition echoed those sentiments: “After nearly two years of waiting for this NCA to be opened, it is unacceptable that CMS has taken this course of action, and the ITEM Coalition implores CMS to open an NCA for power standing systems at the earliest possible opportunity.”


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