Date: Friday, August 19, 2022
By Rita Stanley, RESNA Fellow and Chair, Government Affairs Committee
The life of an advocate can be challenging and frustrating at times. This summer, advocates were expecting to take a big step forward on Medicare coverage for power seat elevation and power standing modules. CMS had committed to open the National Coverage Determination (NCD) on Mobility Assistive Equipment (MAE) this month (August 2022) for public comment on both of these technologies.
RESNA published its first position paper on the application of wheelchair standing devices in 2009, and the first position paper on the application of seat elevating devices in 2010. These initial papers have been updated numerous times, as more evidence has been published regarding the efficacy of these devices to improve the health and well-being of wheelchair users.
CMS has long denied coverage of seat elevation and power standing claiming they were not primarily medical in nature. In September 2020, the ITEM Coalition submitted a formal request for reconsideration of the policy that could reverse the policies regarding these technologies. ITEM member organizations including RESNA, United Spinal, The Christopher and Dana Reeve Foundation, and other groups like the Clinician Task Force and NCART have worked together to convince CMS that these technologies meet medical and functional needs, as well as improve the health, safety, and well-being of Medicare beneficiaries. Advocates held a meeting with CMS officials to walk through the formal request and present the evidence. It was a meaningful and important step when the formal request was accepted as complete. We were not expecting the lengthy wait ahead of us.
Two years later, while we remained cautiously optimistic and hopeful, CMS finally opened the comment period on Tuesday, August 16th – but for seat elevation only. In the announcement, CMS specifically asked for evidence “to determine the use of power seat elevation in association with Group 3 power wheelchairs for the purpose of performing non-level transfers is a medical function.” In addition, and with much disappointment, CMS stated that the “benefit category and coverage of standing systems would be considered at a later date”, but failed to indicate a timeline.
The public comment period for seat elevation closes on Wednesday, September 14th. RESNA, along with our partners, will be submitting comments – and expressing disappointment in the decision to defer power standing review. We believe strongly that people who have a medical need for these items have already waited too long for access. But as advocates, we must remain committed and maintain pressure on CMS to take steps to facilitate timely access to this technology. Victory in obtaining a change in the coverage for seat elevation is obtainable, but it’s not here yet. And we still have much farther to go.
If you’re interested in joining the GAC and participating in our advocacy efforts, and have an inexhaustible supply of optimism and determination, please contact me at firstname.lastname@example.org. Knowledge about public policy and legislative efforts is not required; all you need is a desire to engage!