A Creative Approach to Complex Rehab

It is important during these tumultuous times that complex rehab technology (CRT) providers, manufacturers and other CRT stakeholders stay current on issues that have an impact on access to CRT. Here’s an update with the latest information on key topics and a review of what lies ahead.

CRT & COVID-19

While the dust has settled on most needed COVID-19 policy changes and clarifications, the challenges of evaluating, assembling, fitting, adjusting, maintaining and repairing CRT will continue. The related operational, financial and safety issues present major hurdles for CRT providers as they work to maintain timely and professional services to the children and adults with disabilities who depend on CRT for their function, independence and health.

The good news is that the dedication and commitment of the clinicians, providers, manufacturers and others involved in the CRT provision process has been evident across the country. This dedication and the ability to be flexible and creative will lay the foundation for continuing to provide quality services and products in the months ahead.

CRT Manual Wheelchair Accessories

There was big win for CRT access in December when Congress passed legislation to do two things: (a) provide an exemption from the Medicare Competitive Bidding Program (CBP) for CRT manual wheelchairs and accessories; and (b) provide an 18-month suspension of Medicare inappropriately applying CBP payment rates to CRT manual wheelchair accessories from Jan. 1, 2020 to June 30, 2021.

The July 1 Medicare Fee Schedule reflects these new payment rates and suppliers can use the “KU” modifier when billing CRT manual wheelchair accessories for dates of service starting July 1. For previous claims submitted from Jan. 1 to June 30, suppliers can resubmit for a retroactive payment adjustment through a streamlined resubmission process. Details can be found at homecaremag/crtupdate.

Remote Services Options

Thankfully, during the COVID-19 pandemic, Medicare and many Medicaid and commercial insurance programs permitted the use of telehealth for clinicians and other remote services for CRT providers. As part of advocacy work in this area, the National Coalition for Assistive and Rehab Technology (NCART) published “COVID-19 Advisory: Use of Remote Technology Required During Pandemic to Protect People with Disabilities Access to Needed Complex Rehab Technology.” This outlines the basis and application of telehealth and other remote services in relation to CRT. It also includes a decision tree developed by the Clinician Task Force, a national group of physical and occupational therapists with CRT expertise. It provides clinical guidance on the triaging of CRT clients when using remote technology; you can obtain a copy at ncart.us.

There is no doubt that the appropriate and effective use of telehealth and other remote services can play an important role in maintaining needed access to CRT. While not applicable to all situations, these options can be used for evaluations and consultations and to reduce the need for in-person encounters. A consortium of CRT stakeholder organizations will be working on making telehealth and other remote services a permanent option after the public health emergency expires.

Power Seat Elevation & Standing

Members of the ITEM Coalition (a national organization of consumer, disability and clinician groups) have been meeting with the Centers for Medicare & Medicaid Services (CMS) over the past 18 months to establish Medicare coverage of power seat elevation systems and power standing systems used with CRT power wheelchairs. These systems are currently classified by Medicare as non-covered. ITEM work groups are in the process of finalizing a formal “Request for Reconsideration of the National Coverage Determination for Mobility Assistive Equipment” that will be submitted to CMS. The request will present evidence to support the coverage of these items as a Medicare benefit and will require a formal review and decision by CMS. The objective is to get Medicare beneficiaries the same access to this specialized equipment that other individuals with disabilities have in many Medicaid and commercial insurance plans.

State CRT Legislation

Over the years, passing legislation at the state level has been an important component of establishing recognition that CRT represents specialized equipment and requires focused safeguards and policies.  Seven states already have passed CRT-related legislation: Colorado, Connecticut, Illinois, Oklahoma, Tennessee, Washington and Wisconsin. The good news is that CRT legislation has been introduced in Michigan in the form of Senate Bill 855. Passage of this bill will provide benefits to both Medicaid recipients with disabilities and to the Medicaid program.

You can get more information on the bill and how to help with its passage at protectcrt.org. If you wish to pursue CRT legislation in your state, please contact NCART for strategies and tools.

The ADA at 30

On July 26, the country will be celebrating the 30th birthday of the Americans with Disabilities Act (ADA). To commemorate the signing of this major legislation, NCART is promoting an ADA30 campaign to celebrate the many improvements the ADA has created for people with disabilities and to educate legislators and policy makers about the critical role that access to CRT plays.

NCART and its partners have created a dedicated website at access2crt.org; the campaign will run through the end of July. To help share the message, NCART released a video featuring retired U.S. Sen. Tom Harkin, a recognized disability rights champion.

One of the original sponsors of the ADA, Harkin was a true leader for the rights of people with disabilities during his 40 years in Congress and continues that mission today. Special thanks go to U.S. Rehab and the Harkin Institute for Public Policy for their involvement in the video production.

Our annual National CRT Awareness Week will follow August 10-14. This initiative is designed to create opportunities for providers, manufacturers, clinicians and consumers to share and promote the importance of CRT access.

NCART Membership

During these challenging times it is critical to have an effective national CRT industry association. If your organization provides or manufactures CRT and is not yet an NCART member, please join. We are exclusively focused on CRT advocacy at the federal and state levels and have a proven record of leading and collaborating with others to protect access and secure needed policy changes. Check out the membership area at ncart.us for details or please contact us.

Looking Ahead

It is hard to predict the future, but we know CRT challenges will continue. The COVID-19 pandemic will have a major impact on federal and state budgets. And the new protocols and challenges will necessitate renewed advocacy, creativity and collaboration.

The issues ahead include:

• continued limited access to evaluation and deliveries due to closures;
• health concerns;
• higher operating costs and lower productivity for providers;
• potential state Medicaid budget cuts; and
• decreased CRT manufacturer and provider revenue into the summer and fall.

The needed solutions include:

• increased federal support to avoid state Medicaid program cuts;
• Further CRT/durable medical equipment (DME) Provider Relief Fund payments;
• make permanent the “temporary” Medicare CRT manual wheelchair accessory payment policy;
• delay the upcoming Medicare DME CBP for one year; and
• make permanent the policies allowing telehealth for physical and occupational therapists and allowing remote services for CRT providers.

NCART and the other dedicated industry organizations are here for you and will continue to work hard to ensure people with disabilities have timely access to CRT and the needed supporting services. If you have not already done so, get signed up to receive CRT Alerts at access2crt.org. This will ensure you receive timely updates on issues and actions that impact the availability and provision of CRT.