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 complexrehabtech@gmail.com or posted to a dedicated project blog at http://complexrehabtech.blogspot.com.
Comments are requested by March 31.
