A chronological list of CTF Actions are listed below, with a brief sumamry of the action.
First Month Purchase Option
2009: Medicare beneficiaries currently have the option to purchase a power wheelchair in the first month of medical need. The Clinician Task Force (CTF) believes that language that eliminates this option will have a severe negative impact on the most vulnerable population of our communities.
2007: The President’s budget includes a recommendation that would “establish a 13-month rental period for power wheelchairs”. CTF requests the Senate Finance Committee retain first month purchase option for power wheelchairs in the Medicare package under development. Oppose language and provisions analogous to Section 608 of former House CHAMP Bill
2004: CTF responds to Joseph Shapiro, All Things Considered, and NPR’s coverage, Wed, 12/1/04, All Things Considered, Medicare Cracks Down on Power-Scooter Payments, by Joseph Shapiro
June 2009: CMS seeks comments regarding the burden associated with the final rule, CMS-3017-F (71 FR 17021), which was published on April 5, 2006 and became effective on June 5, 2006. The rule defines who may prescribe PMDs, requires a face-to-face examination of the beneficiary, a written prescription and receipt of pertinent parts of the medical record by the supplier within 45 days after the face-to-face examination. CTF responds.
In the Home restriction
May 2005: Medicare put into effect a more restrictive guidance that strengthens an “in the home” need limitation for people who require any form of mobility device. 2008: Until CMS considers a coverage policy that eliminates the “in the home” restriction, the needs of individuals with functional mobility impairments cannot be fully addressed.
Local Coverage Determination
June 2009: CTF recommends the addition of a coverage option for wheelchair seating that is based on clinical indicators (functional and medical need) for those beneficiaries who do not have one of the current qualifying diagnoses, but are at risk for seating complications.
2005: CTF addresses the draft Local Coverage Determinations (LCD) for Power Mobility Devices (PMDs) as released by the Durable Medical Equipment Regional Carriers (DMERCs) on August 26, 2005.
Medicare Modernization Act, face-to-face requirement
Sept 2004: Clinician Task Force provides CMS the following comments regarding the proposed DME coverage rules regarding CMS-1429-P Section 302; “Physicians need to be aware of other disciplines and consultants who can provide more in-depth assessment and training and assist with prescription of assistive technology. Physicians treating persons with disabilities should understand that an interdisciplinary team approach is often necessary to deal with the multifaceted problems facing these patients. Primary physicians should make sure that knowledgeable consultants, providers, and technology suppliers are readily available to help them meet their patients’ needs.”
National Coverage determination
On May 5, 2005, the Centers for Medicare and Medicaid Services (CMS) released a final Decision Memorandum and revised National Coverage Decision (NCD) for Mobility Assistive Equipment (MAE). In this decision memo, CMS notes “the evidence is adequate to determine that mobility assistive equipment (MAE) is reasonable and necessary for beneficiaries who have a personal mobility deficit sufficient to impair their participation in mobility-related activities of daily living (MRADL) such as toileting, feeding, dressing, grooming, and bathing…” While CMS did adopt functional criteria for this policy, an improvement on the previous bed or chair confined language, the agency did not go far enough. Serious limitations in the decision memo and the NCD remain.
August 2008: CTF addresses issues of reimbursement for therapy services related specialty evaluations and treatment for those requiring complex rehabilitation technology.
2006: CTF provides comments regarding the proposed priorities outlined in the Federal Register Document regarding reuse of AT devices to improve cost savings.
***Roles and Responsibilities (position paper)The assessment, evaluation and technology selection for an individual requiring a wheelchair, seating and related accessories involves a team of professionals with different skills and training backgrounds. At a minimum the team is comprised of the patient, a clinician and a supplier. The clinician and supplier each have very specific and distinct responsibilities because of their different educational and training backgrounds.
November 2005: The Clinician Task Force writes the Centers for Medicare Management to express member concerns and make recommendations regarding Supplier Quality Standards under the competitive bidding program.