RAMP: ‘We Are Heading Towards a Train Wreck’

WASHINGTON–Following last week’s Open Door Forum and release of
the DMERCs’ LCD on power mobility equipment, a strong response from
the Restore Access to Mobility Partnership, an industry coalition
of powered equipment manufacturers and providers, emphasized that
the scheduled Oct. 25 implementation of CMS’ new interim rule on
power mobility should be delayed.

“CMS has a responsibility to clarify procedural guidelines, as
well as outline clear and concise documentation responsibilities,”
a RAMP statement said. “Failure to do so could cause the collapse
of the power mobility industry, creating layoffs, forcing suppliers
to stop selling mobility products and leaving thousands of Medicare
beneficiaries without a means to obtain mobility equipment.”

“We are heading towards a train wreck,” stated Pride USA’s
President Dan Meuser. “We spent more than a year working with CMS
to come up with a new coverage policy. But now all that hard work
is in jeopardy if the coverage policy is not accompanied by a clear
and concise set of regulations to govern how power wheelchairs and
scooters get to the Medicare beneficiaries who need to address
mobility deficits. CMS needs to review the many, many implications
that have not been thoroughly considered. There is no way these new
procedures are ready to be implemented by October 25, as is
currently planned.”

The coalition and its members, which include the American
Association for Homecare, Invacare Corp., The Med Group, Mobility
Products Unlimited, Pride Mobility and Sunrise Medical, also
expressed other concerns.

“How can CMS possibly think about implementing new procedures
when there are so many indications that they are not ready, and
there are important missing pieces?” questioned Mal Mixon,
Invacare’s chairman and CEO. “There needs to be an extensive
education process for doctors and other stakeholders, but that
cannot begin until all the pieces are finalized. The Open Door
Forum was an opportunity for stakeholders … to raise our concerns
about the new procedures. Now, CMS needs to slow down, carefully
listen to our concerns and respond with a revised rule that is
shaped with our input.”

One of the coalition’s biggest concerns is “CMS’ decision to
place more responsibility for documentation with physicians, and to
rely on their chart/patient notes for documentation of medical
necessity for mobility equipment. … This scenario assumes that
the physician has extensive knowledge of the range of mobility
equipment,” the statement said.

“Traditionally, this has been a team approach with the doctor,
clinician and supplier working together on providing the best piece
of equipment for the patient,” said Michael Hammes, chairman and
CEO of Sunrise Medical. “CMS is shifting much of the burden to
doctors, whose primary responsibility is to look at the broader
health of the patient.”

Yet another issue is how to make the transition from the old
coverage policy to the new one, according to RAMP. At the Open Door
Forum, details about the 30-day period cited in the interim rule as
the timeline from a physician face-to-face exam to a decision on
the equipment being delivered were left unclear. “There also seemed
to be an assumption by CMS that physicians are familiar with the
new coverage policy that was introduced in the spring, even though
there has been no education program to inform them,” the statement
said.

“Since the new coverage policy was released, we have said that
clear documentation requirements have to be established. That has
yet to happen,” said John Ward, CEO of Mobility Products, adding
that the interim rule “that CMS is trying to rush into place by
October 25 is an attempt, but it lacks the kind of details that are
needed. CMS must take the time to consider all the consequences and
get this right.”