Activity Revs Up on Separate Rehab Benefit

BUFFALO, N.Y. — Complex rehab technology does not yet
belong to its own distinct category, but rehab professionals from
throughout the sector are continuing their efforts to make that a
reality. Building a case through deliberate steps, NCART Executive
Director Don Clayback, who is coordinating the efforts of the
Separate Benefit Category Steering Committee, hopes Congress will
see fit to carve out a separate Medicare benefit for CRT outside of
the broad category of DME.

Last week, the group released a lengthy proposal on creation of
such a benefit and is currently seeking comment. The 31-page
document is a follow-up to its original March 2010
discussion paper.

The group undertook the effort, Clayback said, because of the
“significant challenges” that stem from increasing coding, coverage
and payment problems that threaten access to CRT. During an Oct. 4
webinar to bring stakeholders up to date, he outlined the steering
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.

In addition to a review of past activities, the full proposal
(available at www.ncart.us) includes a new draft CRT Stakeholders
Bill of Rights and a CRT Service Delivery Matrix along with a
definition of CRT, an evaluation requirement decision tree for
beneficiaries seeking wheeled mobility and an initial list of
existing HCPCS codes that would be classified as CRT.

Among other changes, the proposal would:

• Base coverage criteria for CRT “on the functional and medical
  needs of the beneficiary, rather than on specific diagnosis codes,
  specific categories of diagnoses, or other highly prescriptive
  criteria.”
• Require that only accredited CRT companies be able to provide
  and bill CRT products.
• Exempt all CRT products and services from competitive
  bidding.
• Require strengthened supplier quality standards for companies
  providing CRT. CRT suppliers must have the capability to service
  and repair the products they sell and “must employ (as a W-2
  employee) at least one qualified rehab technology professional
  (RTP) per location.”
• Eliminate Medicare’s controversial “in the home” restriction
  for CRT.

Paul Tobin, president and CEO of the United Spinal Association
and a member of the steering committee, outlined a dozen bullet
points of the proposed CRT Stakeholders Bill of Rights. Among its
points, the document states consumers need “a choice of quality
equipment and services and to have input in the evaluation,
selection, and procurement processes” and “access to a thorough
evaluation by qualified clinicians and suppliers.”

Tobin wants to keep the CRT Bill of Rights as brief as possible,
then rally support among many diverse groups. “Our hope is to have
a one-page document with many pages of endorsements,” said Tobin.
(The draft Bill of Rights is available on page 19 of the
proposal.)

According to NCART President Gary Gilberti, the new separate
benefit proposal represents the culmination of six months of work
since the discussion paper was issued.

“During that time there has been a great deal of discussion and
outreach among consumers, clinicians, suppliers and manufacturers,”
Gilberti said. In addition, he noted, the initiative got a major
boost in July with an endorsement from
the ITEM Coalition, a consumer-led group comprised of more than
70 member organizations in the areas of disability, aging, labor,
voluntary health associations, non-profit provider associations and
others.

“The awareness of the importance and benefits of complex rehab
technology is increasing,” Gilberti said. “That’s a very positive
thing.”

As outlined by the committee from an equipment perspective, CRT
usually includes individually configured manual wheelchair systems,
power wheelchair systems, adaptive seating systems, alternative
positioning systems and other mobility devices that require
evaluation, configuration, fitting, adjustment or programming.
These products and services are designed to meet the specific
medical and functional needs of an individual with a primary
diagnosis resulting from a congenital disorder, progressive or
degenerative neuromuscular disease, or from certain types of injury
or trauma.

“This type of specialization gets lost in the broader
categories,” said Clayback during the hour-long webinar. “We need
to determine how CRT is coded, what are the coverage criteria and
how are items paid for as far as the fee schedule.”

Clayback said the specific legislative language needed to create
a separate benefit is being drafted and should be available
shortly. Once a draft is prepared, the language will be shared with
other stakeholder groups and key offices in Congress for additional
refinement — and the process of having a bill introduced will
begin.

“The idea would be to finalize this language once we have
broader input and opportunity for leaders in Congress to engage,”
said Clayback. “We would take that language and have it crafted
into a bill, find a member of Congress to introduce that bill and
then gather cosponsors. We would hope to have that bill attached to
a broader piece of legislation sometime probably in the spring of
next year where it could come to the floor for a vote and get
passed.”

The steering committee includes representatives from six
national organizations: NCART, the American Association for
Homecare, the National Registry of Rehab Technology Suppliers
(NRRTS), the Rehabilitation Engineering and Assistive Technology
Society of North America (RESNA), the Clinician Task Force (CTF)
and the United Spinal Association.

“We are making real progress,” said Clayback. “The pressing need
for better recognition at the federal and state levels of the
individualized service delivery process relating to CRT and the
benefits of CRT for people with disabilities makes this initiative
a necessity. We will be continuing our outreach efforts and working
with Congress and other policymakers as we move ahead to secure a
separate benefit category.”

Clayback and steering committee members will repeat the webinar
on Tuesday, Oct. 12, at 5:00 p.m. ET. To register, go to: https://www2.gotomeeting.com/register/533518211.

Download a copy of the draft proposal at www.ncart.us.