Committee Asks for Feedback on Separate Complex Rehab Benefit

BUFFALO, N.Y. — A 26-page “discussion paper” and four
hours of details via two Webinars Thursday kicked off continuing
efforts by the project steering committee in development of a
separate benefit for complex rehab technology.

The committee’s five objectives: 1) clearer and more consistent
coverage policies; 2) stronger and more enforceable supplier
standards; 3) formal recognition of product-related services and
costs; 4) payment stability; and 5) an improved coverage and
payment system that can serve as a model for Medicaid and other
payers to follow.

“The separate benefit is a major undertaking, but something
major is needed to protect the availability of these products and
services to people that use them every day of their lives,”
according to committee member Gary Gilberti, president of NCART.
“With this document we can now have the necessary stakeholder
discussions with other individuals and groups to develop the plans
and actions required.”

The discussion paper, in the works since September through the
efforts of a 20-person workgroup, essentially gets the ball rolling
for comments from all relevant stakeholders.

“This is not a finished product,” said Don Clayback, NCART
executive director and steering committee chair. “It is meant to be
a starting point so stakeholders have some level of detail to
review and respond to.”

In a Q&A session during each Webinar, listeners did respond
with questions and comments related to the plan’s major components,
which cover:

Products and coding – Current HCPCS codes will
be classified as Complex Rehab Technology (CRT) and will only be
available through accredited CRT companies. Modifications and
additions will be made, as needed, to codes that currently contain
both CRT products and non-CRT products to segregate CRT from DME,
and new codes will be added for “uncoded” CRT items that are
routinely provided but currently do not have an assigned code.

Coverage and documentation – Coverage criteria
for CRT will be based on a determination of the beneficiary’s
functional abilities and limitations instead of specific diagnoses.
The primary weight for clinical documentation will be shifted from
the physician to the therapist, and Medicare’s “in-the-home”
restriction would not apply to CRT.

Payment – A payment methodology will be
established for CRT that adequately covers both the product costs
and the related service costs that are associated with the
provision of these devices. Avalere Health Group, a Washington,
D.C.-based consulting firm, is helping to identify the potential
options and the preferred methodology to pursue.

Supplier quality standards – A company that
offers CRT must also be able to service and repair all equipment it
supplies. These companies must employ at least one qualified rehab
technology professional (RTP) per location. A qualified RTP is an
individual who has completed the RESNA ATP exam and has fulfilled
“additional requirements.” Those requirements may include obtaining
the RESNA SMS (seating and mobility) certification, or obtaining an
enhanced NRRTS CRTS credential, or meeting other similar
requirements that might be developed by the industry and profession
in conjunction with CMS.

Clayback acknowledged that while everyone may not agree, he and
other committee members — including representatives from
NCART, AAHomecare, NRRTS, RESNA and the Clinician Task Force
— will look carefully at all the feedback during the month of
March and will include the best suggestions on the additional fixes
and changes to the proposal that are needed.

Then the committee plans to report back to the complex rehab
community once again.

“The idea of the separate benefit is to get it implemented
within the Medicare program, and once we have a template we can
then share that with other payers such as Medicaid agencies or
private payers,” said Clayback. “We can say that for these products
and for these people that use them, here is a program that
addresses the coverage, coding and the payment issues that are
involved.”

Read the discussion paper on NCART’s Web site.

Written comments can be submitted to [email protected]
or posted to a dedicated project blog at http://complexrehabtech.blogspot.com.

Comments are requested by March 31.