A Medical Device Daily

Restore Access to Mobility Partnership (RAMP; Washington), a group of suppliers and manufacturers of power wheelchair and scooters, have concluded that the National Coverage Determination (NCD), which outlines a new Medicare coverage policy for mobility equipment (Medical Device Daily, May 9, 2005), requires clarification and changes, it said, “to ensure appropriate access to power wheelchairs and other mobility products for people with disabilities.”

The organization issued a statement last week calling on the Centers for Medicare and Medicaid Services (CMS; Baltimore) to issue interim guidance “as soon as possible” to the Durable Medical Equipment Regional Carriers (DMERC) – the organizations that process Medicare claims – to eliminate the possibility that the new coverage policy will produce “severe problems” before additional companion regulations are released.

While RAMP said that while the policy outlined in the NCD represents progress – such as decisions by CMS to eliminate its “bed- or chair-confined” requirement and to establish more function-based coverage criteria – “more work needs to be done.”

Mal Mixon, chairman and CEO of Invacare (Elyria, Ohio), said in the RAMP statement that the new policy is “an opportunity” making it more possible for beneficiaries to received appropriate mobility equipment, adding: “But we are not there yet.”

To be truly effective, he said, the new coding guidance needs additional “guidelines and regulations that fill in the gaps.” The industry wants an end to vague and ambiguous regulations that can create inconsistency “in claims review” to avoid further barriers to providing the mobility equipment.

RAMP said that a primary area of difficulty comes from the CMS “focus on the establishment of mobility-related activities of daily living and the need for caregivers to provide compensation for beneficiaries incapable of independently performing these daily activities. CMS’ intentions are unclear with respect to the impact of mobility limitation on completing the activities of daily living. “The organization said CMS failed to establish “mobility for mobility’s sake as an activity of daily living that can trigger coverage for mobility equipment.”

Michael Hammes, chairman and CEO of Sunrise Medical (Carlsbad, California), emphasized the need for such clarifications and the need to avoid “inappropriate interpretations” in claims processing. “In fact,” he said, “it was the need for clarification of the old policy that created the last 18 months of pain for suppliers, beneficiaries and the DMERCS.”

RAMP said that CMS could answer “outstanding questions” by issuing national guidelines for definitive documentation requirements” for suppliers.

And RAMP termed NCD “indecisive” in several areas, raising the possibility that Medicare beneficiaries may continue to be underserved until either CMS or the DMERCs clarify how the new coverage policy will actually be implemented.

For instance, the NCD states that one of the coverage guidelines is that the mobility equipment prescribed must “restore the beneficiary’s ability to participate in mobility-related activities of daily living such as toileting, feeding, dressing, grooming, and bathing in customary locations in the home.’’

The group said the wording leaves open the question of what other mobility-related activities of daily living will be considered. If there is going to be a consistent coverage policy that is followed in all the regions, this provision should be clarified so that everyone, particularly the DMERCs, understand what additional activities of daily living will trigger coverage of mobility equipment for Medicare beneficiaries.

RAMP said it will continue its efforts in a variety of ways:

  • Work with CMS and the DMERCs to identify areas of concern, and propose possible solutions.
  • Stress that a new documentation policy, as well as other regulations, should be quickly established to make the new coverage policy applicable.
  • Continue to assist clinicians and advocacy groups in seeking changes to issues, such as the in-the-home restriction and mobility for mobility’s sake, which were not addressed in a satisfactory manner in the new coverage policy.
  • Ask that language in the coverage policy that is too open to interpretation be clarified in subsequent regulations to avoid problems that existed with the previous policy and could render the new one equally ineffective.