ST. LOUIS — Complex rehab stakeholders who gathered in St. Louis last week to talk about a separate complex rehab benefit left the all-day consensus conference with three main take-aways: It needs to be done, there is much work yet to do and it is doable.
That was good news for the Complex Rehab Steering Committee, which hosted the conference and got the green light from some 50 attendees to go ahead with efforts to redefine the complex rehab Medicare benefit.
"I would say the biggest message was, 'You guys are on the right track.' We had consensus that this is something we need to do," said Don Clayback, executive director of the National Coalition for Assistive and Rehabilitation Technology Suppliers and a member of the steering committee.
The event offered stakeholders the opportunity to express their concerns and comment on the work of the steering committee and its work groups, which focused on such issues as fee schedule and coding, medical policy, claims processing and provider qualifications.
"We're trying to flesh out the details through the industry so that we can put those details together into a plan to create a redefined benefit for complex rehab," explained Tim Pederson, CEO of WestMed Rehab in Rapid City, S.D., and chair of the American Association for Homecare's Complex Rehab and Mobility Council.
He added, "I don't see us taking it out of the DMEPOS benefit." Instead, he and Clayback said, a reconfigured benefit might look a lot like the orthotics and prosthetics benefit that falls under DMEPOS.
"They are under the DMEPOS category, but they have their own coverage criteria," Clayback said.
One of the key issues of the day was the definition of complex rehab. "There is broad agreement on all the bullet points that define complex rehab; however, we have not been able to reach consensus in the industry on the wordsmithing of the definition," Pederson said. "There was some division on the steering committee on whether we should focus on the technology for the definition or [on] the process," he continued. "Is it the products or the process? What we determined is that it is both. We really can't define one without the other. So we are going back to the drawing board and try again."
Clayback said the definition would ultimately cover technology/products, users, the process and qualifications of people involved in the process.
Other discussion centered on how the industry can work with CMS and its contractors to change the regulatory arena and elevate the industry, Pederson said.
"There are certain items we are going to pursue through the regulatory process and certain items we are going to pursue through the legislative process," he said. "One of the main things we can do with CMS is to develop a front-end mechanism that identifies a complex rehab supplier, which we don't have right now."
While quality standards require that a RESNA-certified ATP be involved in the wheelchair selection for a patient, Pederson said, "right now, there is no edit system in place to identify whether an ATP was involved."
National Supplier Clearinghouse forms do not have any way to document that the provider is a complex rehab supplier, he noted. "It seems silly to have that requirement and not have a way to document it," Pederson said.
Stakeholders are also concerned, he said, that the complex rehab provider qualifications and accreditation need "some teeth."
"Even though we have quality standards, there is a degree of separation on the application of those standards, and among the surveyors, there are varying methods. We need a little more uniformity and a more robust process," Pederson said.
As well, he noted, a RESNA registry of certified ATPs would be helpful. "We came up with recommendations for RESNA, the NSC, accreditation bodies and for the DME MACs that we can do now and they will immediately elevate our industry exponentially," Pederson said.
Clayback said it was likely some issues would require legislative action. "So we are looking now toward legislation, identifying champions, doing more outreach to the consumer and clinician sides," he said. "We are looking at probably a two-year project from legislation to implementation and operation. Some of the changes could go into effect in 2011."
The conference was the fourth in a series of events sponsored by the steering committee — including two Webinars and a session at Medtrade — to gather feedback, and other Webinars are planned.
"The go-forward plan … is to pull all that together into a summary document with a proposed definition that people will be able to comment on," Clayback said. "We will be creating kind of a white paper that will flesh out some of these details, and we will be sharing it with the industry and other groups through Webinars later this month."
The goal of the steering committee, he stressed, is to be transparent in its work, to invite input from every stakeholder and to draft a plan that will generate consensus.
"I truly think there is going to be consensus in the industry," said Julie Piriano, director of rehab industry affairs for Exeter, Pa.-based Quantum Rehab. "I'm really looking forward, once we get this defined, to looking for legislative champions to take the ball and run with it so we can fully effect change to this benefit."
