NCART is fully supportive of improving safeguards around Medicare payments for power mobility devices (PMDs) and agrees that changes are needed in certain areas. However, the development of these changes should include input from beneficiaries, clinicians and suppliers. Once developed, changes should be announced with sufficient detail and advance notice to allow for an orderly implementation so as to not hurt beneficiary access.
Our primary comments regarding the Medicare Power Mobility Demonstration Project announced by CMS on November 15, 2011 are as follows:
- We recommend CMS move to implementing a “supplier submitted” (not physician submitted) prior authorization system for all Standard power mobility on a national basis. The system should follow that outlined in legislation recently introduced in Congress through the FAST Act (HR‐3399) that focuses on additional safeguards for power wheelchair claims. It is impractical and unnecessary to delegate the administrative act of submitting a prior authorization request to the physician.
- We recommend that Complex Rehab power wheelchairs be excluded from the Demonstration Project and from any prior authorization system. These power wheelchairs (Group 3 and above) should not be included given the additional safeguards and requirements already in place (specialty evaluation requirement, ATP requirement), the small number of claims (only 7% of total power wheelchair claims), and the lack of any history of fraud and abuse. While some Group 3 power wheelchairs are excluded, this exclusion should apply to all Group 3 power wheelchairs.
- We recommend CMS work with clinicians and suppliers to update and improve existing physician educational materials regarding coverage and documentation and use these as part of an expanded national educational program.
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Release Date: 23-Jan-2012
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.