Last week, the Board of Directors of the National Registry of Rehabilitation Technology Suppliers (NRRTS) called on its registrants and the industry to contact members of Congress about the first-month purchase option for power mobility devices.
NRRTS submitted written testimony to the House Ways and Means Committee expressing the organization’s deep concern with President Bush’s proposal to eliminate the first-month purchase option for PMDs provided to Medicare beneficiaries.
In an e-mail dated Feb. 22, NRRTS encouraged registrants and friends of NRRTS to contact members of Congress expressing concerns about the proposal to force all PMDs to be rented for 13 months and its impact on the clients served.
“Special attention should be given to House members who sit on the Ways and Means Committee,” said Simon Margolis, NRRTS executive director, “This committee has already begun their scrutiny of President Bush’s proposed budget.”
Following are the written comments presented by NRRTS:
The best practice standard of our industry and profession is that custom Powered Mobility Devices (PMDs) and other Complex Rehab and Assistive Technology product are not rented to clients — they are sold — including in the price the added value of appropriate evaluation, product selection, fitting, face-to-face delivery, follow-up and service. If the president’s budget proposal is accepted as written, allowing for rental only for PMDs, then only the most generic products will be available that won’t necessarily meet the complex needs of needs of Medicare beneficiaries with significant physical and functional impairments. Access to appropriate PMDs will inevitably be denied by this policy. We do not believe this is the president’s intent.
Due to significant upfront costs and increased cost resulting from recent policy changes, Medicare beneficiaries will lack adequate access to power mobility devices if a 13-month rental is required.
There are significant upfront costs associated with the provision of complex power mobility systems. Individuals with disabilities often require wheelchairs that are configured specifically to meet their unique needs. This need may arise due to anatomical anomalies, seating or positioning needs, or the need for alternative drive mechanisms for individuals who cannot use a traditional joystick. There is a significant service component associated with assessing an individual’s needs. It can often involve simulation to ensure that the technology that is being recommended will adequately meet the needs of the individual. These costs plus the significant equipment cost is borne by the supplier prior to submitting a claim to Medicare.
Recent changes to quality standards and coverage guidelines for power mobility are increasing supplier costs. These new quality standards mandate that in order to provide complex rehab and assistive technology to Medicare beneficiaries the supplier shall employ at least one qualified rehab technology supplier (RTS) or be certified as a RTS per location. A qualified RTS is an individual that is or has one of the following credentials: certified rehab technology supplier (CRTS), assistive technology supplier (ATS) or assistive technology practitioner (ATP). In addition, the rehab technology supplier shall have at least one or more trained technicians available to service each location appropriately depending on the size and scope of its business.
The coverage policy for power mobility devices (PMD) implemented in November of 2006 requires that by April 2008 suppliers providing complex rehab power mobility products must have an ATS on staff that is directly involved in the selection of the wheelchair for the individual.
Representatives of our industry and profession have worked closely with CMS and its contractors to develop these requirements and believe these requirements are essential in any effort to ensure the best clinical outcome for individuals who require the use of this technology. However, it is important to understand that these changes will bring additional cost to suppliers of this technology.
There have been numerous changes to the power mobility benefit over the last two years starting with the requirement in the MMA that individuals have a face-to-face evaluation by a physician in order to qualify for a device. In addition, the new PMD policy requires that the individual be evaluated by a physical or occupational therapist if they need a complex power mobility device. The supplier is required to perform a home assessment to ensure that the home is accessible for the recommended device. The supplier is also required to collect significant information from the patient’s medical record to maintain on file and available to Medicare on demand. These changes have all increased the cost of providing power mobility devices.
Additionally, the PMD policy implemented approximately 60 new HCPCS codes and a new Medicare fee schedule was developed for those codes. The result was a reduction in reimbursement for power mobility devices. The coding changes have also required suppliers to provide substantial education to their referring physicians and clinicians in order to ensure that they understand the new coding and coverage guidelines and to ensure that documentation developed is accurate and adequate to meet Medicare’s coverage requirements. Again, this has increased cost to suppliers.
Medicare beneficiaries prefer to purchase their power mobility devices when their need is long-term. Historically, over 95 percent of Medicare beneficiaries chose to purchase their power wheelchair when given the option upfront. The current definition within the Medicare guidelines for the category “inexpensive or other routinely purchased DME” states, “Routinely purchased DME is defined as equipment acquired by purchase at least 75 percent of the time.” Statistical data from the SADMERC proves that power mobility devices exceed this requirement. Currently, Medicare beneficiaries have the option of renting their power wheelchair if they prefer.
NRRTS strongly advises that the option to purchase power wheelchairs continue to be available to Medicare beneficiaries. If a 13-month rental is mandated, access will be denied to the most needy of Medicare beneficiaries.
