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Hashtag #CRTACCESS2019
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2019 National CRT Leadership & Advocacy Conference
Conference Workbook Table of Contents
General
Welcome Letter
Conference Sponsors
Conference Schedule
Summary of Presentations
Platinum Sponsor Ads
Attendee List
Presentation Handouts
Handout‐ Medicare Sets The Tone
Handout‐ Holding Medicaid Managed Care Organizations Accountable
Handout‐ CRT Outcome Reporting
Handout‐ Medicare Competitive Bidding
Handout‐ Grassroots Advocacy At Home
Advocacy Materials
2019 CRT Congressional Asks
Congressional Visits Info and Tips
Map of Capitol Hill
Position Paper‐ Pass Complex Rehab Wheelchair Legislation
Position Paper‐ Pass CRT Separate Benefit Category Legislation
List of Supportive National Organizations
Share Your Sessions and Visits ‐ Use Hashtag #CRTACCESS2019
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May 1, 2019
Welcome conference attendees!
Thanks very much for taking the time to join us at this year’s National CRT Leadership and Advocacy Conference. It’s great to come together to protect and promote access to Complex Rehab Technology (CRT) for people with disabilities who rely on it.
NCART and NRRTS hold this conference to bring CRT stakeholders together in one place for high value education, networking, and advocacy. With the start of the new Congress this is the perfect opportunity to renew our work to get legislation passed to stop Medicare from applying Competitive Bid pricing to CRT Manual Wheelchair Accessories and to create a Separate Benefit Category for CRT within the Medicare program.
Thank you to our generous sponsors! This conference could not happen without the continued financial support of dedicated CRT manufacturers and providers. Please review the Sponsor Page and be sure and thank them for their continued support to promote and protect access. And very special thanks to the consumers, clinicians, and other advocates who have come to personally visit with their Members of Congress.
We continue to make progress in increasing CRT awareness in Congress and moving our CRT legislation forward. Our past Washington conferences and activities have played a major role in that effort. This is the time to be calling on the new Congress and nothing sends a stronger message than you investing the time to meet with them in their D.C. offices.
We want this CRT Leadership and Advocacy Conference to continue to serve as a catalyst for more effective information sharing, collaboration, and advocacy and sincerely look forward to your active participation. Please let us know if we can be of any assistance.
Best regards,
Don Clayback NCART Executive Director 716-913-4754 [email protected]
Weesie Walker NRRTS Executive Director 404-401-0780 [email protected]
Share Your Sessions and Visits - Use Hashtag #CRTACCESS2019
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PLATINUM SPONSORS
GOLD SPONSORS
SILVER SPONSORSAction Seating/Cimarron Medical Services
ATLAS and ATLAS RPM BodypointEasy Stand
InvacareMonroe WheelchairMotion Composites
Ride Designs
Ki MobilityPermobil
Sunrise MedicalUS Rehab
University of Michigan Wheelchair Seating Service
THANK YOU TO OUR 2019 SPONSORS!
#CRTACCESS2019
2019 NATIONAL CRT
LEADERSHIP & ADVOCACY CONFERENCE
MAY 1 - 2
EDUCATE ADVOCATE LEGISLATEHOSTED BY NCART AND NRRTS
RENAISSANCE ARLINGTON CAPITAL VIEW HOTEL • ARLINGTON, VA.
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Hosted by NCART and NRRTS | Renaissance Arlington Capital View Hotel
Wednesday May 1 Second Floor Ballroom Level
7:30 AM to 1:00 PM Registration Pick up your materials on the Second Floor Ballroom Level.
7:30 AM to 8:30 AM Break Coffee, tea, juice, water available.
8:30 to 8:50 AM “Welcome and Opening Comments”
8:50 to 9:20 AM “No limits. Just a Smile for Miles.”
9:30 to 10:30 AM “Medicare Sets the Tone”
10:30 to 11:00 AM Break Coffee, tea, juice, water available.
11:00 to 12:00 PM “Holding Medicaid MCOs Accountable”
12:15 to 1:20 PM “Bootcamp Lessons and CRT” (Box Lunch Provided)
1:30 to 2:30 PM “On the CRT Radar”
2:40 to 3:30 PM “Advocacy at Home…Where the Rubber Meets the Road”
3:30 to 4:00 PM Break Coffee, tea, soda, water available.
4:00 to 5:30 PM “Congressional Prep and State Delegations”
Get oriented for the next day’s Congressional meetings and coordinate with others from your state.
6:00 to 7:30 PM CRT United Reception Join the party! Food, drink, and conversation will allow everyone to relax and enjoy each other’s company.
Thursday May 2 Second Floor Ballroom Level
9:00 AM to 5:00 PM Capitol Hill Visits We’ll all be heading to the Hill to deliver the CRT message and gain cosponsors to support our bills.
6:00 to 7:30 PM Debriefing Reception Join for a recap of the day’s visits and hear some personal highlights. A great wrap up at the end of a busy day!
2019 National CRT Leadership and Advocacy Conference
May 1 ‐ Leadership Day Sessions
1.) 8:30 to 8:50: “Welcome and Opening Comments”
2.) 8:50 to 9:20: “No limbs. Just a Smile for Miles.”‐ Gabe Adams has been traveling the country and sharing the extraordinary story of his life and overcoming its challenges. Born without limbs to a single and poor mother in Brazil, he faced a bleak future with limited options. However, divine intervention brought word of him to his future adoptive parents in the United States, where he embarked on a journey of courage, perseverance and a dedication to inspire others. He’ll share his experiences along with his motto: “No limbs. Just a smile for miles.” Speaker: Gabe Adams
3.) 9:30 to 10:30: “Medicare Sets the Tone”‐ Medicare continues to be a major influencer regarding health care policy and coverage. This session will review the relationships of HHS, CMS, and Congress and identify the points of influence. Recent Medicare and Medicare Advantage policy changes and those being discussed around supplemental benefits for people with complex needs will be presented. Attendees will also be provided updates on ongoing work with CMS, including efforts to secure Medicare coverage of power seat elevation and standing components. Speakers: Henry Claypool and Peter Thomas
4.) 11:00 to 12:00: “Holding Medicaid MCOs Accountable”‐ Managed Care plays an increasing role in state Medicaid programs, but there are rules that must be followed. This session will present the statutes and regulations governing Managed Care Organizations that contract to cover Medicaid beneficiaries. Real‐life examples of violations that inappropriately hurt access to CRT will be reviewed and attendees will learn about the strategies, resources, and advocacy assistance available to resolve them. Speakers: Marge Gustas and Joe Clark
5.) 12:15 to 1:20: “Bootcamp Lessons and CRT”‐ Some would say we have all had our own version of a Bootcamp of sorts with experiences, influences, people, and places that have transformed us. There is much to be learned from Bootcamp because it is one of the most difficult tests of endurance. But at the end it creates an elite team by changing behaviors, thought processes, instilling discipline, and improving the person. This session will walk through the Cadence of Bootcamp and the Transformational Qualities it holds and how to apply them. Speaker: Ty Bello
6.) 1:30 to 2:30: “On the CRT Radar”‐ There’s a lot going on in the world of CRT and this session will cover two topics: CRT
Outcome Data and Medicare’s Competitive Bidding Program. Outcome data is an important area for CRT coverage;
attendees will hear the latest information regarding the Functional Mobility Assessment (FMA) outcome program.
Medicare will be rolling out a new round of Competitive Bidding; attendees will be provided an overview of what
lies ahead. Speakers: Greg Packer and Claudia Amortegui
7.) 2:40 to 3:30: “Advocacy at Home…Where the Rubber Meets the Road”‐ Successful advocacy can take many forms and advocating at the local level can be one of the most effective. But sometimes getting started can be the hardest part! This session will review the strategies, activities, and resources that can be easily employed with some basic planning and effort. Attendees will hear real experiences and walk away armed with the information to be a true CRT champion right from home. Speakers: Gerry Dickerson and Cathy Carver
8.) 4:00 to 5:30: “Congressional Prep with State Delegations”‐ This session will prepare attendees to get the most out of their visits with Congressional offices. 2019 CRT legislation details, key talking points, and supporting documents will be reviewed. Tips on having an effective meeting and the importance of post‐conference follow up will also be presented. Attendees will meet with others from their states so the following day’s meetings can be best coordinated. Speakers: Don Clayback and Congressional Staffer
9.) 6:00 to 7:30: “CRT United Reception”‐ It’s great to be part of a conference that brings together a cross section of CRT Community members all under one roof. After a day full of education and discussion this is the perfect opportunity to cap the day off with some food, drink, and networking. Come ready to relax and enjoy each other’s company before we all tackle Capitol Hill the next day.
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# Last First Organization State
1 Adams Gabe Consumer Advocate UT
2 Amortegui Claudia The Orion Group CO
3 Banz Thomas Ki Mobility WI
4 Barnett Andrea Numotion TN
5 Barrett Charles Adapt Health MD
6 Bayes Bruce Custom Mobility FL
7 Beaulieu Liz HME News ME
8 Bello Ty Team at Work Coaching IN
9 Bennewith Alexandra United Spinal Association VA
10 Berenger Barbara Custom Mobility FL
11 Bernhardt Lorri Clinician Task Force TN
12 Black Rick Ki Mobility WI
13 Blackburn Georgie Blackburn's PA
14 Bonk Ed National Seating & Mobility CT
15 Border Jennifer Consumer Advocate OH
16 Branard Brittany Reeve Foundation OH
17 Brislin Jay Quantum Rehab PA
18 Britton Carey National Seating & Mobility FL
19 Buckley Stephanie National Seating & Mobility TN
20 Budd Kaitlyn Ki Mobility WI
21 Burke Ryan Rifton NY
22 Campanella Jim Numotion FL
23 Carver Cathy Clincian Task Force AL
24 Clark Joe Neighborhood Legal Services NY
25 Clayback Don NCART NY
26 Claypool Henry Claypool Consulting CA
27 Clover‐Nalley Christy Ki Mobility WI
28 Coburn Pete Sunrise Medical IL
29 Cohen Laura Rehab Technology Consultants VA
30 Cole Elizabeth Advocate NH
31 Coltman Brian University of Michigan WSS MI
32 Colyer Kendra Caregiver CO
33 Cunniffe Amy Split Oak Strategies VA
34 Dalzell Sharon Caregiver NY
35 Dalzell Andrea Consumer Advocate NY
36 Davis Andrew NRRTS GA
37 Denison John Numotion NC
38 Dickerson Gerry National Seating & Mobility NJ
39 Egge Sarah Split Oak Strategies VA
40 Fink Todd Therafin IL
41 Fletcher Derek Ki Mobility NC
42 Frank John Ki Mobility WI
43 Garrison Kate Consumer Advocate TX
44 Goetz John Bridge Public Affairs TN
45 Gustas Marge Neighborhood Legal Services NY
2019 National CRT Conference Attendees by Last Name
Page 1 of 4
# Last First Organization State
2019 National CRT Conference Attendees by Last Name
46 Hale Jeramy Caregiver CA
47 Hale Molly Consumer Advocate CA
48 Harmon Denise National Seating & Mobility IL
49 Harris Mike Action Seating and Mobility OK
50 Havel Tim Numotion MN
51 Henderlong Donelle Consumer Advocate IN
52 Hodges Annette NRRTS TX
53 Howard Joe Numotion CO
54 Ibarra Rafael National Seating & Mobility GA
55 Jackson Alex Consumer Advocate SC
56 Jackson Julie Invacare OH
57 Jankowski Lori Consumer Advocate MD
58 Johnson Seth Quantum Rehab VA
59 Johnson Taylor Susan Numotion SC60 Kalk Debra Reliable Medical MN
61 Kaluf Yumna Caregiver MD
62 Kaluf Luna Consumer Advocate MD
63 Keiderling Joe Rifton NY
64 Kennedy Susan Numotion CO
65 Kiger Angie Sunrise Medical VA
66 King Corey Caregiver SC
67 Kosh Matthew Bodypoint WA
68 Kozak David Kozak And Salina CT
69 Lee Mickae NCART NY
70 Lieberman Jenny Mount Sinai Hospital NY
71 Lizotte Lori Bodypoint WA
72 Long Madonna Quantum Rehab NV
73 Loughner Hannah Monroe Wheelchair NY
74 Mahncke Tyler VGM IA
75 Maichuk Jennifer Monroe Wheelchair NY
76 Mapes David Numotion TN
77 McClurg Lauren Caregiver DC
78 McClurg Peyton Consumer Advocate DC
79 McGowan Scott Custom Mobility FL
80 McKnight Joe Numotion CA
81 McMahon Michelle Frontier Access WY
82 Michael Erin Clinician MD
83 Miles Angel Consumer Advocate IL
84 Miller John Miller's OH
85 Mitchell Melissa Consumer Advocate WA
86 Monger Jill Clinician Task Force SC
87 Morgan John Invacare MS
88 Munaker Jacob Advocate VA
89 Munsey Doug Ki Mobility WI
90 Newsome Allen Senior Mobility Aids CA
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# Last First Organization State
2019 National CRT Conference Attendees by Last Name
91 Newsome III Allen Senior Mobility Aids CA
92 Niquette Marita Consumer Advocate MA
93 Nordquist Mike Ki Mobility WI
94 Odom Amy NRRTS TX
95 Packer Greg VGM IA
96 Papac Jim Levo MN
97 Patrick Caitlin Advocate OH
98 Peebles Ryan National Seating & Mobility TN
99 Perlich Nancy Easy Stand MN
100 Peterson Brad Invacare OH
101 Pottol Kristy DEKA Research MD
102 Powers Tom VGM IA
103 Raccosta Samuel Consumer Advocate NJ
104 Raccosta James Caregiver NJ
105 Racicot Diane National Seating & Mobility MI
106 Raphael Charlie RESNA VA
107 Reuter Martin Ki Mobility WI
108 Richardson Justin Numotion NC
109 Roberts Kathryn Stillwater Medical OK
110 Romano Kyle Custom Mobility FL
111 Romano Kris Custom Mobility FL
112 Roy Karen Numotion LA
113 Salina Adam Kozak And Salina CT
114 Salm Richard Ride Designs CO
115 Schmeler Mark University of Pittsburgh PA
116 Schmeler Isabelle University of Pittsburgh PA
117 Seidel Michael Numotion MO
118 Semrad Jackie Reliable Medical MN
119 Sharpe Dennis MK Battery CA
120 Shomer Lew Abilities Expo CA
121 Siegle Jenny Consumer Advocate CO
122 Simon Tom Numotion TX
123 Slater Sheri Consumer Advocate MD
124 Smith Jason MK Battery CA
125 Stanley Rita Sunrise Medical NC
126 Steinbuchel Haley Caregiver AL
127 Steinbuchel Carla Consumer Advocate AL
128 Stephan Kristyn Travis Medical FL
129 Stephenson Jim Permobil OH
130 Stewart Elaine National Seating & Mobility IN
131 Stommes Paula Reliable Medical MN
132 Stone Scott Advocate OH
133 Storie John Quantum Rehab PA
134 Szalay Rene Ki Mobility NV
135 Thomas Peter Powers Law DC
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# Last First Organization State
2019 National CRT Conference Attendees by Last Name
136 Tracy Bret Merits SC
137 Van Brocklin Wayne REP‐Inc VA
138 Verrett Cody Motion Concepts DE
139 Walker Weesie NRRTS GA
140 Walling Todd Permobil TN
141 Walls Ginger Permobil TN
142 Ward Alexis National Seating & Mobility TX
143 Watts Kathy Caregiver IN
144 Wells Scott Sunrise Medical KS
145 Westerdahl Doug Monroe Wheelchair NY
146 Williams Ryan Convaid CA
147 Woodward Stephanie Quantum Rehab NY
148 Wooten Kira Caregiver UT
149 Yang Anthony University of Pittsburgh PA
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Medicare Sets The Tone
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Medicare Sets the Tone
National CRT ConferenceMay 1, 2019
Henry D. Claypool, Principal, Claypool Consulting
Peter W. Thomas, JD, Principal, Powers Law Firm
Working With Congress
• Medicare related committees
– Senate: Finance Committee
– House: Ways & Means Committee; Energy and Commerce Committee
• Medicare FFS improvements
• DME "in the home"
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Working With Executive Branch
• Department of Health and Human Services (HHS)
– Important agencies and offices
• Centers for Medicare and Medicaid Services (CMS)
– Structure of the agency
– Leadership offices
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Medicare Wheelchair Benefit• Since Operation Wheeler Dealer began in 2001, there
has been major changes in coding, coverage and payment– Elimination/denial of key codes that help beneficiaries access titanium, bariatric and other specialty wheelchairs
– NCD for MAE: Concept of coverage algorithm and MRADLs (mobility itself not being one of them)
– Competitive bidding to reduce reimbursement and limit number of suppliers
– These changes have compromised access, quality and choice for Medicare beneficiaries with mobility impairments
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What about Improvements?• Congress, HHS and CMS have done virtually NOTHING in the past 20 years to improve the mobility device benefit:
– Dramatically cut reimbursement and access to care through CB
– Extended CB pricing to Medicaid
– Rejected coverage of the iBOT™ Mobility System
– Never seriously considered amending “in the home” requirement
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But Progress Has Been Made….
• Competitive Bidding exemption for CRT (2008)
• Exemption of CRT power accessories (2017)
• Nearly enacted exemption for CRT manual (Still being considered)
• Strong Congressional support for separate CRT category legislation
• Delays of implementation of CB
• Extension of blended reimbursement
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Medicare Sets The Tone
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New Coverage Proposals
• Coordinated campaign to have Medicare program cover seat elevation and standing feature in power wheelchairs
• Strong legal arguments that these functions should be considered “DME”
• They are not because MACs have determined they are not “primarily medical in nature.”
• Not a question of medical necessity (NCD/LCD)
• This is a benefit category determination (BCD)
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Arguments for Coverage
• These features are vital to performance of MRADLs, which is the NCD’s coverage standard– Why is tilt/recline medical in nature but seat elevation and standing feature are not?
• They are embedded in the power mobility device itself, which makes them DME under HCFAR 96‐1
• Seat lift mechanism is covered but seat elevation in mobility devices is not
• Medical benefit of standing is widely demonstrated in the literature
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ITEM Coalition Taking the Lead
• ITEM is a 75‐member coalition run by a steering committee of consumer/disability groups and supported by many in the room– Steering Committee: United Spinal, Reeve Foundation, PVA, NMSS, and Amputee Coalition
– Thank you NCART, AAHomecare, Smith & Nephew, Pride, Permobil, Numotion, and Sunrise
–Mission is to advocate for access to and coverage of assistive devices and technologies of all kinds across the lifespan
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Status of Coverage Initiative
• Spring/Summer 2018: Developed comprehensive legally‐based request to CMS Administrator for reconsideration of BCD for seat elevation and standing feature
• August 2018: Submitted request to CMS• October 2018: Met with CMO Kate Goodrich• February 2019: Met with CMS Principal Deputy and
team to answer questions• April 2019: Met with Office of the HHS Secretary• Requesting CMS issue decision on its own authority• If not, we will go to Congress
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Off‐the‐Shelf Orthotics
• Recent DOJ announcement of $1.7 billion fraud scheme involving orthotics
• 24 defendants, 5 telemedicine providers, 3 physicians, and 130 DME companies
• Medicare O&P Patient‐Centered Care Act soon to be introduced to address this and other O&P access issues
• OTS orthotics (23 codes) is scheduled to be part of competitive bidding in 2021 for first time
• Fear is that the clinical services will be lost and orthoses will be drop shipped to patient’s homes without any assessment, fitting, follow up, or training
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Non‐Invasive Ventilators in CB
• NIV is also scheduled to be included in CB 2021• ITEM opposes inclusion of NIV in CB program• ITEM is working in 2019 to exempt NIV from CB through
CMS or Congressional action• Partnering with other patient (ALS) and professional
organizations to elevate issue• NIV would be first CB service designated as requiring
frequent and substantial servicing• These beneficiaries are at risk under NIV CB• Medicare costs will likely increase as inpatient admissions
and complications increase for these patients
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Medicare Sets The Tone
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IRF OIG Report• HHS OIG published damaging report in October 2018 claiming an
84% error rate in 2013 IRF claims• This equates to a $5.7 B Medicare overpayment
– This conflicts with 17% error rate found by CERT– Highlights the subjectivity and unreliability of IRF medical necessity
audits– Referred to as the “Goldilocks” standard
• AMRPA, AAPM&R, the Federation and AHA have all pushed back hard on this report but…..
• This is driving concern that CMS will implement the OIG recommendation to impose prior authorization for IRF services in the traditional Medicare program
• Prior Auth in the Medicare Advantage program is, in part, responsible for MA patients having 1/3 the access to IRF care that traditional Medicare beneficiaries have.
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Prior Authorization (PA)• Prior authorization for IRF fee‐for‐service care
– This would be a disaster for patients and providers alike– Timeliness of services and access to care would be severely impacted.
• OIG also published in September 2018 a report on the use of prior authorization in Medicare Advantage (MA):– Currently 21 M MA beneficiaries (32 M expected by 2028)– OIG found that 95% of prior auth. denials that were appealed were reversed in favor of providers, suggesting PA is a delay and deny tactic
– OIG seriously questioned the utility of PA in MA plans
• Bipartisan House legislation will soon be introduced to address expedited and electronic PA in MA plans
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Questions?
Henry D. Claypool
Principal, Claypool Consulting
Peter W. Thomas, J.D.
Principal, Powers Law Firm
[email protected] 202‐466‐6550
www.powerslaw.com
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Medicaid Managed Care
1
Holding Medicaid Managed Care Programs Accountable
Presented by
Joseph D. Clark, Esq.and
Marge Gustas, Paralegal
Neighborhood Legal Services, Inc., Buffalo, New York
Overview of Medicaid Managed Care Plans
• Waivers pursuant to the Social Security Act §1915 (b)
• Demonstration Projects pursuant to the Social Security Act § 1115
• Social Security Act § 1932(a) State Option to Use Managed Care
Overview of Medicaid Managed Care Plans
Federal Regulations Related to the Provisions of MMC Services
Federal definition of DME 42 C. F. R. § 440.70
Federal MMC regulations42 C.F. R. Part 438
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Medicaid Managed Care
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Overview of Medicaid Managed Care Plans
Model Contracts and the Provision of
Medicaid Managed Care Services
Can be found on‐line
Incorporate much of the state law
into the terms of the contract
Overview of Medicaid Managed Care Plans
Common Problems with MMC and Prior Approval
• Use of internal policies and procedures that are narrower than the federal or state statutes.
• Narrower definition of medical necessity.
• Failure to review request under Medicaid’s Early and Periodic, Diagnostic, Screening and Treatment Services.
• The use of non‐medical reviewers or medical reviewers of a different medical discipline than the treating practitioner.
Overview of Medicaid Managed Care Plans
NCART Pilot Project at
Neighborhood Legal Services
Here’s who we are and
here’s what we are doing!
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Medicaid Managed Care
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Overview of Medicaid Managed Care Plans
What Can You Do to Protect the Rights of Your Consumers?
• Reach out to your local P and A’s
• Reach out to your local Legal Services offices
• Make sure that PTs, OTs, and SLP are aware of how MCOs should be evaluating their requests
• Bring new issues to the attention of the Pilot Project via Don Clayback
Thank You!
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CRT Outcome Reporting
1
What Do Rehab Outcomes Mean to the World of Healthcare
CRT Leadership Conference
May 1, 2019
Greg Packer, President, U.S. Rehab
Who is U.S. Rehab
• A division of the VGM Group, Inc.
• VGM Nearly 1000 employees
• 100% employee owned since 2008
• 25 and counting business units
• 400+ U.S. Rehab members
Functional Mobility Assessment (FMA)
• Web‐based outcomes program
• U.S. Rehab/University of Pittsburgh
• Full spectrum of mobility consumers
What is the Functional Mobility Assessment (FMA)?
•Collect and de‐identify data•Analyze•Reports provided to participating providers
So, what does a provider need to do?
• Time 1 Intake and FMA at Initial Evaluation
• Enter data into website• FMA.USRehab.com
• Enter delivery information
• Be responsive if any issues arise
That’s it!
Follow‐ups conducted by U.S. Rehab on your behalf
• Time 1 (Baseline)• Initial Evaluation
• Time 2• 21 days after delivery
• Time 3• 90 days after delivery
• Time 4• 180 days post delivery
• Time 5• 1 year post delivery
• Time 6• 2 year post delivery
Not to be re-distributed without permission from primary authors
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CRT Outcome Reporting
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Intervention
Time 3
Initial Intake and FMA at Evaluation
Time 2Time 1 Time 4 Time 5 Time 6
Delivery Information provided or collected by FMA Follow-Up Personnel
Delivery
21‐Day post‐delivery follow‐up
90‐day follow‐up
6 month follow‐up
12 month follow‐up
Annual follow‐up
Time 3.1
Medical or equipment issue found at 90 day follow‐up. Follow‐up FMA completed 5 business days after initially found.
User Dashboard
Why do outcomes matter?
• Affordable Care Act (ACA)• Based on person‐centered care
• Evidence‐based practice
• Hospitals and insurance companies beginning to require outcomes
Healthcare requires more accountability and outcomes‐basedinformation, which will be tied to reimbursement
The Findings: Funding Sources
The Findings: Lifetime CostsThe Findings: FMA Scores
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CRT Outcome Reporting
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The Findings: ATP Involvement The Findings: Secondary Medical Complications
The Findings: Patient Re‐admittance The Findings: Device Age
Contact Us
Greg Packer
President, U.S. Rehab
800‐987‐7342
Tyler MahnckeOperations & Business Development [email protected]‐274‐4551
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Medicare Competitive Bidding
* Any portion of this presentation is not to be copied or distributed without explicit consent from Claudia Amortegui. �
The Latest on Competitive Bidding and its Effects on CRT
2019 National CRT Leadership & Advocacy Conference
Presented by: Claudia Amortegui
Taking the guesswork out of reimbursement.
We’re in the CRT world… CBP?
Taking the guesswork out of reimbursement.
It Effects Us!
• Codes – we use the same codes for options as standard mobility
• Allowables – things tend to roll downhill
• Ease for clients ➜ D/C Planners working with multiple product categories
• Access
• What else?
Taking the guesswork out of reimbursement.
CBP “On Hold”
• “Temporary Gap Period” vs. “On‐Hold”
• Original Contract winners – contracts expired 12/31/18
• Single Payment Amounts (SPAs)
• Expected to re‐start on 1/1/21
Taking the guesswork out of reimbursement.
CBP 2021
• No longer Round 1 & Round 2 – Now Round 2021
• Non‐invasive ventilators included in this next round
• Wheelchair Product Category split – Manual vs. Power
• Introduced “Lead Items”
• “Expected” Timeline• May 2019 – CMS announces dates for registration & bidding; begins bidder education program
• June 2019 – Bidder registration period begins; bid window opens
Taking the guesswork out of reimbursement.
Lead Item
• Per CMS: The item in a product category with multiple items with the highest total nationwide (including PR & VI) Medicare allowed charges of any item in the product category prior to each competition.
• No individual bids – bidders will only submit one bid for the lead item, which represents their bid for all the items in that specific product category – this is how CMS will calculate the individual SPAs (allowables) for each item.
Taking the guesswork out of reimbursement.
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Medicare Competitive Bidding
* Any portion of this presentation is not to be copied or distributed without explicit consent from Claudia Amortegui. �
Lead Items
Taking the guesswork out of reimbursement.
Product CategoryLead Item HCPC Code
HCPC Code Description
Commode Chairs E0163Commode Chair, Mobile or Stationary w/ Fixed Arms
Hospital Beds E0260Semi‐Electric Hospital Bed, w/ Side Rails & Mattress
Non‐Invasive Ventilators E0466Home Ventilator, Any Type, Used w/ Non‐Invasive Interface
Patient Lifts & Seat Lifts E0630 Patient Lift, Hydraulic or MechanicalStandard MWCs K0001 Standard Wheelchair
Standard PMDs K0823PWC, Group 2 Standard, Weight Capacity, Captains Chair
Support Surface (Grp 1 & 2) E0277 Powered Pressure‐Reducing Air Mattress
Single Payment Amount- SPA -• Lead Item = the maximum bid submitted for that item by bidders whose bids for the item are in the winning range in that CBA for that product category (i.e. K0001)
• Non‐Lead Items = relative ratio x lead item SPA • Ratios are based on the historic differences in the fee schedule amounts for the lead item and non‐lead item.
Taking the guesswork out of reimbursement.
Single Payment Amount- SPA -A small bit of good news….
• CMS is using the 2015 unadjusted fee schedules (pre‐competitive bid adjusted allowables).
*Providers still need to be smart enough to understand what their one bid really means.
Taking the guesswork out of reimbursement.
Bid Surety Bonds
• All 2021 bidders must purchase a $50,000 bid surety bond for each CBA it will submit a bid for.
• Bond must be purchased from a list of certified companies from the Dept of Treasury website: https://www.fiscal.treasury.gov/surety‐bonds/list‐certified‐companies.html
• Bond must be effective when submitting bids until approximately 90 days after contract winners are announced – should be prior to 1/1/21/*
Taking the guesswork out of reimbursement.
Bid Surety Bonds
Once winning contracts are offered:
• If a contract is offered and the composite bid is at or below the median composite bid – provider must accept offer or forfeit their bond.
• If no contract is offered or if the providers composite bid is above the median composite bid ‐ bond liability is returned.
*Composite bid – providers bid on lead item in a product category.
Taking the guesswork out of reimbursement.
H.R. 2293
Protecting Access to Complex Rehab MWC Act
• Permanently exempts complex rehab MWCs from Medicare’s CBP.
• Medicare would be required to stop applying CB payment rates to options on CRT MWCs for 18 months• Providing us time to work on a permanent change
Taking the guesswork out of reimbursement.
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Medicare Competitive Bidding
* Any portion of this presentation is not to be copied or distributed without explicit consent from Claudia Amortegui. �
A Possible Headache
• Even if CRT is completely carved out…. Billing and proper payment could be an issue – remember the past?
• Same codes used for options on standard mobility & CRT
• SPAs would differ for the same code within CBP for manual vs. power – then add the carve out.
MODIFIER NIGHTMARE!!
Taking the guesswork out of reimbursement.
Presented by:
Claudia Amortegui
www.orionreimbursement.com
DC1
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Grassroots Advocacy
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Grassroots Advocacy
Advocacy at Home – Where the Rubber Meets the Road
Gerry Dickerson, ATP, CRTS
National Seating and Mobility
Cathy Carver PT, ATP/SMS
Clinician Task Force
CRT Conference 2019
Objectives
• Provide Supplier and Clinician perspective on grassroots advocacy
• Provide practical steps to advocacy on the Hill
• Provide practical ideas for advocacy for follow up at home
Grassroots AdvocacyWhy do it?
For the good of the consumer?
Cathy Carver, PT, ATP/SMS & Gerry Dickerson, ATP, CRTS
Grassroots Advocacy
Grassroots Advocacy Grassroots Advocacy
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What the Consumer needed
Grassroots Advocacy
What insurance approved
Grassroots Advocacy
Grassroots AdvocacyWhy Do It?
For yourself?
Grassroots Advocacy
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Grassroots Advocacy
Grassroots Advocacy –As Time Goes By…
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STOP!
READ THIS
You have requested a new custom mobility device from:
_____________________________________________Your insurance at the time of this request is:
______________________________________________
Grassroots Advocacy
Cathy Carver, PT, ATP/SMS & Gerry Dickerson, ATP, CRTS
Grassroots Advocacy
May 1, 2019
ANY change to your insurance before you accept delivery of this
custom mobility device will result in cancellation of this order.
You will need to start the entire process, from the beginning, all over again. Depending on your new insurance , _______, or your seating clinic may not be able to assist you.
Grassroots Advocacy
May 1, 2019
In the event your insurance denies the interventions prescribed by your seating and mobility team, you consent to the following except where noted by checking No;
Grassroots Advocacy
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Grassroots AdvocacyFrom the Clinician
Grassroots AdvocacyPower of the Clinician and Consumer
• Telling the Story of the need for CRT
• Difference between CRT and standard DME
• Why it’s important to have a skilled clinical team involved
• Need for SBC and what that will do
• Consumer – describe how you use your CRT
• What happens if you don’t have it
• Importance of your supplier
Grassroots Advocacy
• The Ask
• Can you think of any questions the Member may have or concerns?
• The Follow up – leave information
• When can I follow up (put it on your calendar)
• How? Email, phone
• Remain steady, respectful, engaged, involve other people
The Follow Up
• Excuses –• Busy• Don’t know what to say• Intimidated
• Someone else can do it
• They won’t listen to me
• They think it’s all about $$• Hard to Explain the bill
National CRT Leadership
and Advocacy
Conference 2019
Grassroots AdvocacyThe Follow Up
ASK Keep up “The Ask” and any concerns why the Member would not sign on…
InviteInvite to your Clinic or Supplier’s office (Clinicians may need permission from employer)
ContactEmail, Call, Visits; from the clinic –send resources to your patients after you see them www.access2crt.org
Others Get others involved – consumers, clinicians, suppliers…everyone!
Grassroots Advocacy
The Hill Home In PersonReporting tool – see handout
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Grassroots AdvocacyWhat if…???
They do Sign on…
They don’t respond after numerous tries of calls, emails, attempts to meet…
Grassroots AdvocacyResources
NRRTS
NCART
www.access2crt.org
Others
Grassroots Advocacy
Grassroots AdvocacyTHANK YOU!!!
May 1, 2019
Cathy Carver, PT, ATP/SMS
Gerry Dickerson, ATP, CRTS
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2019 CRT Congressional Asks
Pass Legislation Needed to Protect Access for People with Disabilities
Congress is urged to protect access to Complex Rehab Technology (CRT) for people with disabilities by passing two critical bills in 2019. CRT products include specialized wheelchairs, seating systems, and other adaptive equipment used by people with significant disabilities such as ALS, cerebral palsy, multiple sclerosis, muscular dystrophy, spinal cord injury, and traumatic brain injury. This equipment is individually configured to meet their unique medical needs, maximize their independence, and reduce their health care costs.
CRT is provided through a clinical team model and labor‐intensive process that includes evaluation, simulation, assembly/configuration, delivery, fitting, programming, and training. Once delivered, it must be supported with ongoing adjustment, maintenance, and repair. An introductory video on CRT can be found at www.access2crt.org.
Unfortunately, the ability for this small population of people with disabilities to access this specialized technology and supporting services is being threatened. Congressional action is needed this year.
PRIORITY 1: Cosponsor and Pass H.R. 2293 and S. ______ to Stop Inappropriate Application of DME
Competitive Bid Program Rates to Complex Rehab Manual Wheelchair Accessories.
Representatives John Larson (D‐CT) and Lee Zeldin (R‐NY) have introduced H.R. 2293 to stop CMS’ inappropriate application of Medicare Competitive Bid Program pricing to accessories (a/k/a critical components) used with CRT manual wheelchairs. Senators Bob Casey (D‐PA) and Rob Portman (R‐OH) have also introduced S. ______ to provide similar protection. The issue relating to CRT “power” wheelchair accessories was addressed with a CMS policy correction back in 2017, but the “manual” wheelchair accessories problem is a lingering issue that has not been resolved. Passage of this legislation is needed to fix the disparity for people with disabilities who use a CRT manual wheelchair as they currently do not have the same access to accessories as those using a CRT power wheelchair.
PRIORITY 2: Cosponsor and Pass H.R. ______ to Establish a Separate Benefit Category for Complex
Rehab Technology and Provide Needed Comprehensive Improvements.
The “Ensuring Access to Quality Complex Rehabilitation Technology Act” has been re‐introduced by Representatives Jim Sensenbrenner (R‐WI) and Brian Higgins (D‐NY). Problems continue to grow because these specialized CRT items are grouped within Medicare’s “standard” DME category. The bill will create a separate category for CRT within the Medicare benefit just like the one that exists for Orthotics and Prosthetics (custom braces and artificial limbs). It will also provide needed coverage, coding, and safeguard improvements focused on the needs of people with disabilities. Over 50 national patient, consumer, and medical professional organizations have formally communicated their written support to Congress.
Position papers, cosponsor lists, email and phone call links, and
educational material regarding this legislation is available at www.protectmymobility.org.
For additional information on Complex Rehab Technology visit www.ncart.us.
Congressional Visits Info and Tips
Congressional Building Information
House Office Buildings (Independence Avenue)
Cannon (CHOB) ‐‐‐ Dining in Room B114‐ smaller cafe
Longworth (LHOB) ‐‐‐ Dining in Room B223‐ largest cafeteria on House side
Rayburn (RHOB) ‐‐‐ Dining in Room B357‐ smaller cafe
Senate Office Buildings (Constitution Avenue)
Hart (HSOB) Dirksen (DSOB) ‐‐‐ Dining found on the basement level‐ largest cafeteria on Senate side
Russell (RSOB) ‐‐‐ Dining found on the basement level‐ smaller cafe
Congressional Meeting Protocol and Follow Up
1.) Start with why you are there: “We are in Washington as part of a National Conference asking
Congress to protect access to specialized equipment (Complex Rehab Technology) that people
with disabilities depend on to reduce healthcare costs and maximize independence.”
2.) Introduce yourselves and convey why the Member should care: Who are you; who do you
represent (votes); give personal perspective on importance of CRT.
3.) Review the issues and the “ASKS”: (Priority 1) Stop Medicare from inappropriately applying
DME Competitive Bid pricing to Complex Rehab Manual Wheelchair Accessories – Cosponsor
and pass HR‐2293 and S‐______; (Priority 2) Create a Medicare Separate Benefit Category for
CRT to provide separate recognition and comprehensive improvements in coverage and
safeguards – Cosponsor and pass HR‐______.
4.) Ask if there are any questions and respond as needed: If they ask something you do not know,
it’s fine to just acknowledge that and indicate that you will get back to them with an answer.
5.) Ask for Commitment: If they need to review further, ask if you can follow up in a week to get
the answer. If they say they won’t sign on, find out why. Don’t be argumentative, but give a
friendly counter/alternative and restate you really need their support.
6.) Identify and carry out (or delegate) needed follow up: Remember your follow up is KEY. Polite
persistence wins the day. Follow up post‐conference to secure their commitment.
CRT Conference Break Room ‐‐‐ We have a “break room” for attendees open from 9:00 AM to 3:00 PM
in the Longworth House Office Building ‐ Room 1604.
Emergency Contact Numbers ‐‐‐ Weesie Walker at 404‐401‐0780; Amy Odom at 806‐781‐8932; and
Mickae Lee at 585‐784‐0208.
See U.S. Capitol Map on Reverse Side.
GUided ToUrS of The CapiTol Tours are free, but tour passes are required. 8:45 a.m. – 3:30 p.m., Monday – Saturday
Tours may be booked in advance online at www.visitthecapitol.gov, through the offices of your Senators or Representative, or through the Office of Visitor Services by calling 202.226.8000.
A limited number of same-day passes are available. Inquire at the Information Desks in Emancipation Hall on the lower level of the Visitor Center.
loCaTion & hoUrSThe Capitol Visitor Center, the main entrance to the U.S. Capitol, is located below the East Plaza of the Capitol between Constitution and Independence Avenues.
Visitors: The Visitor Center is open to the public from 8:30 a.m. to 4:30 p.m., Monday through Saturday. It is closed on Thanksgiving Day, Christmas Day, New Year’s Day, and Inauguration Day.
Official Business: Visitors with official business appointments may enter the Visitor Center as early as 7:15 a.m.
SafeTy & SeCUriTyBefore entering the Capitol Visitor Center, all visitors are screened by a magnetometer and all items that are permitted inside the building are screened by an x-ray device. The following items are strictly prohibited:• Liquid, including water
• Food or beverages of any kind, including fruit and unopened packaged food
• Aerosol containers
• Non-aerosol spray (Prescriptions for medical needs are permitted.)
• Any pointed object, e.g. knitting needles and letter openers (Pens and pencils are permitted.)
• Any bag larger than 18" wide x 14" high x 8.5" deep
• Electric stun guns, martial arts weapons or devices
• Guns, replica guns, ammunition, and fireworks
• Knives of any size
• Mace and pepper spray
• Razors and box cutters
Please note that the U.S. Capitol Police are authorized to make exceptions if a prohibited item is determined to be necessary and required to serve child care, medical or other special needs.
ViSiTorS wiTh diSabiliTieSVisitors may request wheelchairs from Capitol Visitor Center staff wearing red vests or at one of the Coat Check stations just inside the main entrance.
Sign-language interpreting for tours is available when booked in advance. Listening devices with audio description of the films and exhibition are available at the Information Desks. All films have open captioning.
The Office of Congressional Accessibility Services may be reached reached at 202.224.4048 (voice) or 202.224.4049 (TTY).
Routes fRom metRo stations
accessible Routes to the u.s. capitol
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Pass H.R. 2293 and S. ______ to Protect Access
to Complex Rehab Wheelchairs for People with Disabilities
Clarify Exemption from Medicare Competitive Bidding Program
Issue: Since 2015 national consumer, patient, medical professional, and industry advocacy organizations have been working with the Centers for Medicare and Medicaid Services (CMS) and Congress to stop CMS from inappropriately using Medicare Competitive Bidding Program (CBP) pricing to cut payment amounts for critical components (a/k/a accessories) used with Complex Rehab wheelchairs. This application violates Congress’ intent embedded in legislation passed in 2008 (MIPPA) and would take away access for people with significant disabilities who require this specialized equipment. Congress passed temporary delays in 2015 and 2016 and then in 2017 Senators Bob Casey (D‐PA) and Rob Portman (R‐OH), along with Representatives Lee Zeldin (R‐NY) and John Larson (D‐CT), introduced legislation to provide a permanent fix. These bills garnered strong bipartisan support and finished 2018 with 25 and 123 cosponsors, respectively. CMS partially solved the problem in 2017 by publishing a policy clarification stating it would not use CBP pricing for accessories used with Complex Rehab “power” wheelchairs. This resolved the issue for Group 3 Complex Rehab power wheelchairs but did not extend relief to the same critical components/ accessories when used with Complex Rehab “manual” wheelchairs. CBP pricing continues to be inappropriately applied to these items. This creates a major disparity in that people with disabilities who use Complex Rehab manual wheelchairs have less access to critical components than those using Complex Rehab power wheelchairs. There should be equal access for all. It is important to recognize the label “accessories” is a Medicare policy term that does not properly convey that Complex Rehab wheelchair accessories are in fact “critical components” such as seat/back pressure relieving cushions, positioning devices, recline/tilt systems, and specialty controls. These critical components allow the Complex Rehab wheelchair to be individually configured and adapted to meet the unique medical and functional needs of the person with a disability. The negative consequences of the current situation are not limited to just Medicare beneficiaries. They extend to children and adults with disabilities covered by Medicaid and other insurance plans since most payers use Medicare payment policies as their basis for payment. Congressional action is required to provide equal access to those with severe disabilities who rely on Complex Rehab manual wheelchairs. Background: Complex Rehab power and manual wheelchairs along with related critical components are used by a small population of people with significant disabilities such as ALS, cerebral palsy, multiple sclerosis, muscular dystrophy, spinal cord injury, and traumatic brain injury. Within the Medicare program these individuals represent less than 15% of all Medicare beneficiaries who use wheelchairs, but they are a very vulnerable group of beneficiaries. The specialized equipment is provided through a clinical team model and requires evaluation, configuration, fitting, adjustment, programming, and ongoing repair and maintenance. The small population of people who require Complex Rehab wheelchairs have the highest level of disabilities and
require these individually configured wheelchairs and critical related components to meet their medical needs, reduce their health care costs, and maximize their function and independence. Unfortunately, CMS groups heterogeneous products under a single HCPCS billing code; the same code includes both Standard wheelchair components and Complex Rehab wheelchair components. Complex Rehab wheelchair components are different technologically, designed to meet a unique clinical need, and are costlier to provide than Standard products. CMS is taking information obtained through the competitive bidding of components used on Standard wheelchairs and inappropriately applying that pricing to Complex Rehab components that were not part of the CBP. Action Needed: The core issue is the Complex Rehab “manual” wheelchair situation was not addressed in CMS’ 2017 policy correction and still requires a resolution. Accordingly, Congressional action is needed to stop CMS’ inappropriate application of CBP pricing to these Complex Rehab manual wheelchair systems to ensure equal access for the Medicare beneficiaries (and others) with significant disabilities who rely on them. H.R. 2293 has been introduced by Representatives John Larson and Lee Zeldin; their staff contacts are Nancy Powers Perry ([email protected]) and Sarah Talmage ([email protected]), respectively. S. ______ has been introduced by Senators Bob Casey and Rob Portman; their staff contacts are Gillian Mueller ([email protected]) and Seth Gold ([email protected]), respectively.
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The National Coalition for Assistive and Rehab Technology (NCART) works to ensure individuals with disabilities have adequate access to Complex Rehab
Technology and related supporting services. For additional information visit www.ncart.us.
Partial List of National Patient, Consumer, and Medical Professional Groups Supporting Passage
Academy of Spinal Cord Injury Professionals ACCSES
Amer. Academy of Physical Medicine & Rehab American Association on Health and Disability
American Cochlear Implant Alliance American Congress of Rehabilitation Medicine
American Foundation for the Blind American Medical Rehabilitation Providers
American Occupational Therapy Association American Physical Therapy Association
American Therapeutic Recreation Association Amputee Coalition
Assoc. of the Blind and Visually Impaired (AER) Assoc. of Assistive Technology Act Programs
Brain Injury Association of America Caregiver Action Network
Christopher and Dana Reeve Foundation Clinician Task Force
Lakeshore Foundation National Assoc. of Orthotics and Prosthetics
National Assoc. for Support of Long Term Care National Council on Independent Living
National Disability Rights Network National Multiple Sclerosis Society
Paralyzed Veterans of America RESNA
Spina Bifida Association The Arc of the United States
The Myositis Association Unite 2 Fight Paralysis
United Cerebral Palsy United Spinal Association
Pass H.R. ______ to Create Separate Benefit Category for CRT
Needed to Protect People with Disabilities Access to Complex Rehab Technology
Overview A separate benefit category for Complex Rehab Technology (CRT) must be established within the Medicare program to protect people with disabilities’ access to this critical technology and supporting services. These specialized products are currently included within Medicare’s broad durable medical equipment (DME) benefit category which prevents adequate differentiation of CRT devices to facilitate the establishment of focused policies and safeguards. A separate CRT category will allow for needed improvements in coverage policies, coding, and quality standards to better address the unique needs of people with significant disabilities and chronic medical conditions. These individuals rely on CRT products to manage their medical needs, minimize their health care costs, and maximize their function and independence. Background The DME benefit was created over 50 years ago to address the medical equipment needs of elderly individuals. Over time technology has advanced to now include highly configurable manual wheelchairs, power wheelchairs (not the power wheelchairs seen advertised on TV), adaptive seating and positioning systems, and other specialized equipment such as standing frames and gait trainers. This technology – called Complex Rehab Technology – is prescribed and individually configured to meet the specific medical and functional needs of people with disabilities and chronic medical conditions. These highly specialized products and the related services are unique and significantly different from standard DME. Because of the current inclusion of CRT in Medicare’s outdated DME coverage and classification system, there is not a proper segregation of these products and access to CRT is threatened. Current Medicare policies do not adequately address the unique needs of individuals with disabilities, incorporate the complexity and unique nature of the equipment, or acknowledge the full range of services required in the provision of these products by CRT suppliers. The implications of continuing to classify CRT within the traditional durable medical equipment category are stark. Product choice will be limited and critical services will be curtailed. A full range of products and related services may be unavailable to the individual with a disability, jeopardizing access to the most appropriate equipment and necessary supportive services. Complex Rehab Technology Is Significantly Different from Standard DME
Focused on People with Disabilities: Complex Rehab Technology is used by individuals with significant disabilities and medical conditions. The CRT population, who tend to qualify for Medicare based on their disability and not their age, consists of individuals with diagnoses that include, but are not limited to, amyotrophic lateral sclerosis (ALS), cerebral palsy, multiple sclerosis, muscular dystrophy, spinal cord injury, traumatic brain injury, and spina bifida.
Requires More Clinical/Supplier Personnel, Services, and Time: Complex Rehab Technology requires a broader range of services and specialized personnel than what is required for standard DME. The provision of CRT is conducted through an interdisciplinary team (referred to as the CRT Team) consisting of, at a minimum, a physician, a physical therapist or occupational therapist, and a rehab technology professional (RTP). Devices in this category typically require a clinical evaluation completed by a licensed clinician that identifies the medical and functional needs along with a technology assessment completed by a certified RTP employed by a CRT supplier. The technology assessment involves determining the products and configurations to address the medical and functional needs identified by the clinician. Simulation or equipment trials are often used to ensure that the items are
appropriate and will meet the individual’s requirements. Because CRT equipment is complex and in order to meet the specific needs of the individual, the provision process is much more labor and resource intensive than that for standard DME items. This includes the activities of evaluating, selecting, assembling, delivering, fitting, adjusting, training, and education. In addition, Medicare requires environmental assessments within the home for certain CRT products.
Uniqueness of CRT Devices: These products are individually configured to meet the unique needs and abilities of a specific person. Many of the products require a clinical evaluation, a technology assessment, measuring, fitting, simulations and trials, a mixing and matching of items from different manufacturers, significant training and education, and refitting and additional modifications. The devices also require ongoing maintenance and repairs.
Requires Credentialed Staff: The Medicare program requires that CRT suppliers employ specialized and credentialed staff to analyze the needs of individuals with disabilities and assist in the selection of the appropriate equipment. These credentialed personnel, called Assistive Technology Professionals (ATP), are certified by the Rehabilitation Engineering and Assistive Technology Society of North America (RESNA) and specialize in the assessment, selection, configuration, and provision of CRT products.
More Comprehensive Quality Standards: The Medicare program has established quality standards that all DME companies must meet to qualify for participation in the Medicare program. However, CRT suppliers must also meet additional and more rigorous quality standards given the nature of the equipment provided and the beneficiaries served.
Precedents for Treating Individually Configured Devices Differently Congress has acknowledged complex rehab power wheelchairs are unique and more specialized than standard DME. In 2008 it passed legislation exempting these products from inclusion in Medicare’s DME competitive bidding program recognizing that such inclusion would jeopardize access to this customized technology. In addition, Congress has recognized the unique nature of other customized products and services and created a separate category for Orthotics and Prosthetics (O&P), i.e. custom braces and artificial limbs. CMS acknowledged the specialized service component inherent in custom‐fit orthotics and prosthetics and treats O&P as separate and unique with its own medical policies, accreditation standards, and reimbursement calculations. This same distinct recognition and segregation is needed for CRT. Needed Congressional Action Congress must pass H.R. ______ to establish a separate benefit category for CRT products and services within the Medicare program and implement other needed changes. This will allow for improvements in coverage policies, coding, and supplier standards to better address the unique needs of the individuals with significant disabilities and chronic medical conditions who rely on these specialized products and related services to manage their medical needs, minimize their health care costs, and maximize their function and independence. H.R. ______ has been introduced by Representatives Jim Sensenbrenner (R‐WI) and Brian Higgins (D‐NY). The staff contacts are Ben Steinhafel ([email protected]) in Representative Sensenbrenner’s office and Jessica Burnell ([email protected]) in Representative Higgins’ office.
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A listing of over 50 supportive national consumer and medical professional groups along with other information regarding CRT can be found at www.access2crt.org. For additional information,
contact Don Clayback, Steering Committee Chair, at [email protected].
National Organizations Supporting Federal CRT Legislation
“Ensuring Access to Quality Complex Rehabilitation Technology Act”
1) ACCSES2) ALS Association3) American Academy of Physical Medicine and Rehabilitation4) American Association for Homecare5) American Association of People with Disabilities6) American Association on Health and Disability7) American Congress of Rehabilitation Medicine8) American Medical Rehabilitation Providers Association9) American Music Therapy Association
10) American Occupational Therapy Association11) American Physical Therapy Association12) Amputee Coalition of America13) American Cochlear Implant Alliance14) American Therapeutic Recreation Association15) Association for Education and Rehabilitation of the Blind and Visually Impaired16) Association of Assistive Technology Act Programs17) Association of University Centers on Disabilities18) Blinded Veterans Association19) Brain Injury Association of America20) Caregiver Action Network21) Center for Medicare Advocacy, Inc.22) Christopher and Dana Reeve Foundation23) Clinician Task Force24) Disability Health Access25) Disability Rights Education and Defense Fund26) Easter Seals27) Harris Family Center for Disability and Health Policy28) Hearing Loss Association of America29) ITEM Coalition30) Muscular Dystrophy Association31) Myositis Association32) National Association of County Behavioral Health and Developmental Disability Directors33) National Association for Home Care & Hospice34) National Association of State Head Injury Administrators35) National Coalition for Assistive and Rehab Technology36) National Council on Independent Living37) National Disability Rights Network38) National Down Syndrome Society39) National Family Caregivers Association40) National Multiple Sclerosis Society41) National Registry of Rehabilitation Technology Suppliers42) National Rehabilitation Hospital43) Paralyzed Veterans of America44) Perkins School for the Blind45) Rehabilitation Engineering and Assistive Technology Society of North America46) Spina Bifida Association47) TASH48) The Arc of the United States49) United Cerebral Palsy Association50) United Spinal Association51) Unite 2 Fight Paralysis
For more information on Complex Rehab Technology visit www.access2crt.org
