Complex Rehab Organizations Continue Work for Separate Benefit

Believing that a separate Medicare benefit category for complex rehab products and services is critical to meeting the unique needs of people with serious disabilities, a quartet of industry organizations - the American Association for Homecare (AAHomecare); the National Coalition of Assistive & Rehab Technology (NCART); the National Registry of Rehab Technology Suppliers (NRRTS); and the Rehabilitation Engineering & Assistive Technology Society of North America (RESNA) - are continuing to work to secure such a benefit.

AAHomecare, NCART, NRRTS and RESNA are teaming to shoulder both the workload and the cost of the ongoing initiative.

In a late January Webcast, NCART Executive Director Don Clayback - serving as the non-voting chairman of the complex rehab steering committee -- reviewed the organization's ongoing efforts and reiterated the need to separately define and recognize complex rehab technology, the professionals who provide it, the beneficiaries who would qualify for it, and the services closely affiliated with it.

In the presentation, Clayback said the objectives of separating complex rehab from the DME benefit are as follows:

• Clearer and more consistent coverage policies to address unique needs of individuals with disabilities.

• Stronger provider standards to promote better clinical outcomes and consumer protection.

• Recognition of the depth and cost of product-related and clinical services to allow for appropriate funding.

• Payment stability to ensure continued access to products and encourage product development.

• An improved coverage and payment model for Medicaid and other payors to follow.

Acknowledging the scale of the initiative, Clayback identified five areas that would be affected by the creation of a new complex rehab benefit: fee schedules; coverage and conditions for payment; coding; claims processing; and provider qualifications.

For example, if complex rehab equipment is put into a new benefit category, HCPCS coding would be affected. Some current codes would be moved into the new benefit category, and additional codes would most likely be created to accurately identify and describe complex rehab equipment that's now being inappropriately bundled with other products.

Coverage criteria would have to be written to determine which beneficiaries would qualify for the complex rehab benefit, and provider standards and qualifications would need to be determined.

For instance, during the Webcast Q&A session, a caller asked if under the proposed coverage rules, a patient with diabetic neuropathy would qualify for complex rehab. Clayback said coverage would depend on the results of a functionality assessment, and that a patient with diabetes could qualify if functionality was impaired enough to meet coverage criteria. He noted that coverage criteria would emphasize a beneficiary's functionality, rather than be based on a group of qualifying diagnoses such as the ICD-9 list.

Clayback told another Webcast participant that the initiative will include a push to overturn Medicare's current "in-the-home" equipment requirement, and that services affiliated with complex rehab equipment, such as providers being required to repair and service the equipment they sell, would likely be included in complex rehab supplier standards.

So far, Clayback says, a steering committee has been formed, and goals and objectives defined. The committee has worked with an outside consultant, Avalere Health Group, to identify and evaluate various strategies to accomplishing the initiative. AAHomecare, NRRTS, RESNA and the Clinician Task Force are also involved in driving the initiative forward.

Clayback told Webcast participants that the committee is currently developing a white paper and a supporting action plan. The next step will be to review that information with stakeholders, make changes as needed, then begin outreach activities to move the initiative forward.

The next Webinar is scheduled for March 4 at two times: 8:30 a.m. and 5:30 p.m. Eastern time. Go to to learn more about the separate benefit for complex rehab, and to sign up for future updates.

About the Author

Laurie Watanabe is the editor of Mobility Management. She can be reached at

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