Separate Benefit Category Needed for Complex Rehab Technology To Ensure Access

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Position

A separate benefit category for complex rehab technology should be established so that access to this critical technology can be assured. The Medicare durable medical equipment (DME) benefit does not meet the complex needs of individuals who require assistive rehab technology.

Background

The DME benefit was created over forty years ago to address equipment needs of elderly individuals with limited life expectancies. Today’s technology includes complex power wheelchairs, highly configurable manual wheelchairs, adaptive seating and positioning systems, and other specialized equipment, such as standing frames and gait trainers. This technology – called complex rehab technology – is prescribed and customized to meet the specific medical and functional needs of patients with disabilities and medical conditions such as cerebral palsy, muscular dystrophy, and spinal cord injuries. Suppliers who furnish this highly specialized technology provide services and products that are much different from DME providers.

Complex Rehab Technology Is Significantly Different from Standard DME

Population Served: Complex rehab technology is used by individuals with conditions different from the traditional elderly Medicare population. This population group, who tends to qualify for Medicare based on their disability and not their age, consists of individuals with diagnoses of cerebral palsy, muscular dystrophy, amyotrophic lateral sclerosis (Lou Gehrig’s disease), spinal cord injury, and spina bifida.

Complex Rehab Services: Complex rehab technologies require a much broader baseline of services thanwhat is required in the provision of standard DME. Devices in this category require a technology evaluation completed by a certified specialist that involves matching the physical and functional needs with the appropriate technologies. Simulations or equipment trials are often used to ensure that the items are appropriate and meet the patient’s identified needs. Because the equipment is complex and becomes an extension of the patient, training and education requires more time than for basic technology. In addition, Medicare requires home assessments within the home for complex rehab, unlike traditional DME.

Uniqueness of Complex Devices: Each device requires a different evaluation and assessment, measuring, fitting, simulations and demonstrations, mixing and matching of products, refitting and then additional modifications.

Specialized Staff: The Medicare program requires that complex rehab companies employ specialized staff to analyze the needs of individuals with disabilities and assist in the selection of the appropriate equipment. These specialized personnel, called Assistive Technology Professionals (ATP), are certified by RESNA and are unique to complex rehab devices.

More Comprehensive Quality Standards: The Medicare program has established quality standards that all DME companies must meet to qualify for the Medicare program. However CMS has established additional quality standards with which complex rehab technology companies must comply.

Precedent For Treating Customized Devices Differently

Congress has acknowledged complex power wheelchairs are different from traditional DME. In 2008 it passed legislation exempting these products from inclusion in the planned Medicare DME competitive bidding program recognizing such inclusion would jeopardize access to this customized technology. In addition, Congress previously recognized the unique nature of similar customized durable medical equipment in the Balanced Budget Act of 1997. In this legislation, which subsequently became law, Congress recognized the specialized service component inherent in custom‐fit orthotics and prosthetics (O&P) and created a separate and higher reimbursement category for O&P.

Access to Complex Rehab Technology Threatened

Access to complex rehab technology is threatened because of Medicare’s outdated classification system for durable medical equipment. It fails to consider the range of services furnished by complex rehab technology companies and the complexity of the equipment itself. The implications of continuing to define complex rehab technology within the traditional durable medical equipment category are stark. Product choice will be limited and critical services such as simulations may be curtailed. A full range of services may be unavailable to the patient, jeopardizing access to the most appropriate equipment.

Recommendation

The National Coalition for Assistive and Rehab Technology urges Congress to establish a new and separate benefit category for complex rehab technology and services that recognizes the customized nature of the technology and the broad range of services necessary to meet the unique medical and functional needs of people with disabilities.



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Release Date: 15-Jul-2009

About NCART

The National Coalition for Assistive and Rehab Technology (NCART) is an organization of providers and manufacturers that supply products and services used by individuals with complex disabilities and medical conditions.  NCART promotes policies, regulations, and legislation to ensure individuals with complex disabilities and medical conditions have appropriate access to necessary assistive equipment and services.

For additional information visit www.ncart.us or contact Don Clayback, Executive Director, at 716‐839‐9728 or dclayback@ncart.us.