Seat Elevation NCD Reconsideration Central

Additional Resources

CMS announcement (Feb. 15, 2023)

Decision Summary and Link to Comment Site

rise4access.org -- comprehensive resources developed by the ITEM Coalition to assist patients, clinicians, and other stakeholders in commenting on the NCD.

AAHomecare comments on Seat Elevation NCD (submitted March 17, 2023)

Message to Encourage Your Mobility Patients to Comment on Seat Elevation NCD

AAHomecare Comments on CMS NCA for Seat Elevation Systems (Sept. 2022)

Oct. 2021 House of Representatives sign-on letter supporting NCD reconsideration signed by 77 members of Congress.

Oct. 2021 letter supporting NCD reconsideration from Sens. Tammy Duckworth, Marsha Blackburn, and Bob Casey.

Sept. 2020 ITEM Coalition letter to CMS supporting NCD reconsideration signed by AAHomecare and more than 50 other patient and healthcare stakeholder groups.

Aug. 2020 National Council on Disability letter to CMS regarding standing and seat elevation systems.

About the Medicare coverage determination process.

Seat Elevation NCD Reconsideration Central

Your support is needed to help strengthen patient access to highly effective seat elevation systems -- share your comments with CMS by March, 17, 2023

CMS has proposed to cover seat elevation systems in power wheelchairs. The agency will be accepting public comments on the proposal for the next 30 days, with a deadline of March 17, 2023.

Find resources here to help you craft your comments, and encourage others to advocate for coverage for this life-enhancing technology.

The medical benefits of power seat elevation and power standing systems in power wheelchairs are beyond dispute. -- ITEM Coalition, September 2020

Thanks to determined, multi-year efforts of mobility product suppliers and patient advocate groups, CMS is moving forward with a proposal to cover power seat elevation systems under Medicare. AAHomecare joined with the ITEM Coalition, NCART, and other stakeholders to help deliver a strong comment response when CMS asked for input on for updating the National Coverage Determination NCD for seat elevation systems last September. Now we're asking the HME community to help deliver one more powerful endorsement for strengthening access to standing systems for Medicare beneficiaries.

The ITEM Coalition has summarized the CMS proposal and notes that the Agency is also looking for input on including coverage for seat elevation systems used with Group 2 power wheelchairs:

Specifically, the decision proposes to determine that seat elevation systems in Group 3 power wheelchairs are within the benefit category for DME. CMS also proposes to determine that these systems are considered reasonable and necessary for beneficiaries when they are used to perform weight-bearing transfers to/from the wheelchair while in the home, and when the individual has undergone a specialty evaluation by a practitioner with specific training and experience in rehabilitation wheelchair evaluations.

Further, CMS states that the agency is seeking comments on whether seat elevation systems in Group 2 power wheelchairs would be appropriate for coverage as well [emphasis ours].This represents a significant opportunity to potentially expand coverage beyond even our initial request, and we encourage all members to support expanded coverage as well in their comments.

HME stakeholders are encouraged to share comments requesting Medicare to cover this technology and to encourage your patients, clinician partners, and other contacts to comment, too. You can submit comments here through March 17, 2023.

While the most effective comments will incorporate your own words and perspective, we offer these messages on the issue as a starting point:

Identify your role as an HME supplier (or other role) and reference any related work with individuals with significant mobility challenges.
Specifically request that Medicare extend coverage for seat elevation systems in power wheelchairs for individuals with mobility disabilities.
Share any perspectives/experience you are aware of on importance of mobility for individuals in terms of both health outcomes (i.e., such benefits as improved joint mobility and muscle tone, increased strength and bone density, better urinary and digestive health, improved respiratory function, and reduced bedsores), as well as enhanced independence and ability to remain at home.
If possible, reference a specific experience(s) you have that highlight the importance of improved mobility for patients with severe disabilities, as well as any experiences providing these systems to patients, if applicable.
Conclusion: Express your thanks for the opportunity to comment and reaffirm your support for expanding Medicare coverage for seat elevation systems.

AAHomecare is currently developing comments on behalf of the association and will post these here when available. Please encourage your patients, clinicians and other contacts to add their voice to this effort, and share the ITEM Coalition's rise4access.org resource to help in crafting their messages.