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Complex Rehab Technology Initiatives

AAHomecare is committed to advancing mobility and Complex Rehab Technology (CRT) priorities to ensure patient access to the mobility solutions to meet their medical needs and maximize their function and independence.  A small population of people with the highest level of disabilities such as ALS, cerebral palsy, multiple sclerosis, muscular dystrophy, spinal cord injury, and traumatic brain injury require customized and individually figured CRT wheelchairs and critically related components (called “accessories”).  Below are two CRT initiatives currently underway:

•    Exempting CRT Accessories from Competitive Bidding Pricing 
•    Creating a Federal Separate Benefit for CRT

Exempting CRT Accessories from Competitive Bidding Pricing


In November 2014, CMS issued Final Rule CMS 1614-F, which contained provisions relating to Medicare’s DMEPOS benefit.  These provisions detail how CMS will use information obtained through the Medicare Competitive Bidding Program (CBP) to adjust the Medicare fee schedule for competitively bid items provided in non-bid areas.  In December 2014, CMS issued a “Frequently Asked Questions” document, stating that it would begin using CBP pricing information obtained from bids for standard wheelchair accessories to reduce payment amounts for critical CRT wheelchair accessories (such as seat/back cushions, tilt/recline systems, and specialty controls).  The payment changes went into effect on January 1, 2016.  

This is contrary to Congress’ intent and Medicare policies where CMS used its authority to exclude Complex Rehab manual wheelchairs from Competitive Bidding in 2010.  More important, the reduced payment rates create significant access problems for Medicare beneficiaries and other people with disabilities.

Exemption Efforts

Congress has twice passed temporarily delays to the application of CBP pricing to CRT Group 3 power accessories, and CMS permanently excluded them in June 2017.   However, Congressional action is still needed to protect beneficiaries who rely on manual CRT.

On April 12, 2019, Congressmen John Larson (D—CT) and Lee Zeldin (R—NY) introduced HR 2293 which clarified Congress’ intent to exempt all CRT wheelchairs from the Competitive Bidding Program and provides an 18-month delay to Medicare applying Competitive Bidding rates to CRT wheelchair accessories.  On April 29, 2019, Senators Bob Casey (D—PA) and Rob Portman (R—OH) introduced S 1223 Senate companion legislation.

To get involved in exemption efforts, ask your Member of Congress to cosponsor HR 2293 and Senators to co-sponsor S 1223

Creating a Federal Separate Benefit for CRT


The Durable Medical Equipment (DME) benefit was created over 40 years ago to address the medical needs of elderly individuals.  Over time, technology has advanced to now include Complex Rehab Technology, which is prescribed when standard mobility does not meet the individual’s unique and specific anatomical, medical, or functional needs.   CRT includes highly configurable manual wheelchairs, power wheelchairs, adaptive seating & positioning systems, and other specialized equipment such as standing frames and gait trainers.

These highly specialized products and services are unique and differ significantly from their standard mobility counterparts in terms of their design, technology, populations served, and clinical involvement; however CRT is still categorized in the DME benefit in Medicare’s coverage and classification system. 
Without a proper segregation of CRT, patient access is threatened since current Medicare polices do not adequately address the needs of individuals with disabilities, acknowledge the full range of services provided by CRT suppliers, or incorporate the complexity and unique nature of the equipment itself.  This can result in limited product choice and curtailed critical services, thus jeopardizing access to the most appropriate equipment and necessary supportive services.

Separate Benefit Efforts

Congress has acknowledged that CRT differs from standard mobility. 

In 2008, it passed legislation exempting these product from inclusion in the Competitive Bidding Program, recognizing that such inclusion would jeopardize access to this customized technology.  It also passed legislation twice to delay the application of bidding derived pricing for standard wheelchair accessories to be applied to CRT Group 3 power accessories and currently has legislation (HR 2293) to exempt manual CRT accessories as well. 

There is also precedence for this, as Congress has recognized the unique nature of other customized products and services through the creation of the separate classification of Orthotics & Prosthetics (O&P), which have their own medical policies, accreditation standards, and reimbursement calculations.

On April 30, 2019, Congressmen Jim Sensenbrenner (R—WI) and Brian Higgins (D—NY) introduced HR 2408 “Ensuring Access to Quality Complex Rehabilitation Act of 2019”, which  will amend the Social Security Act to establish a separate benefit category for CRT and allows for other required changes to be made to better address the unique needs of end users.

To get involved in separate benefit efforts, ask your Member of Congress to cosponsor HR 2408

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