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.
