As part of our upcoming Roll on Capitol Hill event in Washington, DC on June 25-26, United Spinal Association and NSCIA are urging policymakers to support a separate benefit category for complex rehab technology proposed in the Ensuring Access to Quality Complex Rehabilitation Technology Act of 2012 introduced by Rep. Joe Crowley, D-7th NY.
Complex rehab technology (CRT) refers to products and services, including medically necessary individually configured manual and power wheelchair systems, adaptive seating systems, alternative positioning systems, and other mobility devices that require evaluation, fitting, design, adjustment and programming. Such technology is designed to meet the specific and unique medical and functional needs of an individual with primary diagnoses resulting from a congenital disorder, progressive or degenerative neuromuscular disease, or from an injury or trauma.
The U.S. Congress has acknowledged that complex rehab power wheelchairs are unique and more specialized than standard durable medical equipment (DME) and should be treated differently. In 2008, it passed legislation exempting these products from inclusion in Medicare’s new Durable Medical Equipment (DME) competitive acquisition program recognizing that such inclusion would jeopardize access to this customized technology for individuals with disabilities for whom it is medically necessary. However, a separate CRT benefit structure was not established at that time. The Centers for Medicare and Medicaid Services (CMS) has recognized the unique nature of other customized products and services and has created a separate and distinct classification for Orthotics and Prosthetics (O&P), i.e. custom braces and artificial limbs.
CRT is unique and differs significantly from standard DME in the following ways:
• CRT is used by individuals with disabilities who have medical conditions significantly different from those experienced by the traditional elderly population in Medicare. This population tends to qualify for Medicare based on their disability and not their age and consists of individuals diagnosed with such disorders as Cerebral Palsy, Muscular Dystrophy, Multiple Sclerosis, Spinal Cord Injury, Amyotrophic Lateral Sclerosis (Lou Gehrig’s disease), and Spina Bifida.
• CRT requires a broader range of services and specialized personnel than those required for standard DME. CRT is provided by way of an interdisciplinary team consisting of, at minimum, a Physician, a Physical Therapist or Occupational Therapist, and a Rehab Technology Professional (RTP) –certified by the Rehabilitation Engineering and Assistive Technology Society of North America (RESNA)–referred to as the CRT Team. Devices in this category require a technology assessment completed by a certified RTP employed by a CRT Company.
• Many of the products require a physical evaluation, a technology assessment, measuring, fitting, simulations and trials, a mixing and matching of products from different manufacturers, significant training and education, and refitting and ongoing additional modifications.
• The Medicare program has established quality standards that all DME companies must meet to qualify for the Medicare program. CMS has included additional and more rigorous quality standards with which CRT companies must comply.
Medicare currently does not have unique coverage for the more complex needs of individuals with disabilities and chronic medical conditions that require customized products and services that are medically necessary. We believe the creation of a separate benefit will actually result in decreased Medicare expenditures by averting hospitalizations due to such conditions as severe pressure sores and blood clots. In the interest of quality healthcare and optimal functionality for individuals with disabilities, a new Medicare benefit category is warranted.
Roll on Capitol Hill is United Spinal Association’s annual legislative advocacy event that addresses issues that will directly impact the health, independence and quality of life of individuals living with spinal cord injury or disease.
For more information on Roll on Capitol Hill, please submit your inquiries here.