Proposal Unveiled for Complex Rehab Benefit Category

The steering committee working to establish a separate benefit category for complex rehab last week released a proposal that outlined what that benefit category would be like.

The "Proposal to Create a Separate Benefit Category for Complex Rehab Technology" document comes six months after a March discussion paper and is described as "a report on the progress and details relating to obtaining a separate benefit category under the Medicare program." The steering committee includes representatives from the National Coalition for Assistive & Rehab Technology (NCART), AAHomecare, the National Registry for Rehab Technology Suppliers (NRRTS), the Rehabilitation Engineering & Assistive Technology Society of North America (RESNA), the Clinician Task Force, and United Spinal Association.

The highly detailed proposal includes several exhibits, including a list of HCPCS codes proposed to be defined as complex rehab technology (CRT), a CRT Service Delivery Matrix, a CRT Evaluation Requirement Decision Tree for Beneficiaries Seeking Wheeled Mobility, a draft of a CRT stakeholders' bill of rights, and a definition of CRT.

NCART President Gary Gilberti said when the proposal was released, "The issuance of the proposal represents the culmination of six months of work since the discussion paper was issued in March. During that time, there has been a great deal of discussion and outreach among consumers, clinicians, suppliers and manufacturers. As a result, we have been able to further develop the basis and details of the separate benefit category."

Gilberti added that the ITEM Coalition and its consumer group members have endorsed the benefit category effort. "The awareness of the importance and benefits of complex rehab technology is increasing," he said. "That's a very positive thing."

Part of the separate benefit category effort is the drive to develop clearer, more consistent coverage policies that specifically take into account the individualized needs of consumers who require CRT. Another is to establish an understanding of CRT's service component, which is ongoing and critical to this particular niche.

One proposed change relating to coverage and documentation: "Coverage criteria for CRT will be based on a determination of the beneficiary's functional abilities and limitations, rather than specific diagnoses or other highly prescriptive and limiting criteria."

Another proposed change prevents Medicare's infamous "in-the-home" restriction from applying to CRT.

On the payment end, only companies that are accredited to sell CRT would be allowed to provide and bill for those products, and all CRT would be exempt from any type of competitive bidding program.

Companies that wish to provide CRT would have to adhere to new supplier quality standards, including the requirement that CRT companies service the products they sell, and that each CRT company employ at least one rehab technology professional, who "will be required to show additional evidence of competency in the provision of seating & mobility."

The CRT stakeholders' bill of rights includes the rights of consumers to have a "choice of quality equipment and services and to have input in the evaluation, selection and procurement process" and to have "access to a thorough evaluation by qualified clinicians and suppliers."

To download and read the entire proposal, go to the NCART Web site (, then to the Current Issues section - or click HERE.

About the Author

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

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