Commentary

Editor’s Note: Commenting on CMS’s Seat Elevation Proposed Decision

• By Laurie Watanabe
• Mar 01, 2023

By now, you probably know that on Feb. 15, the Centers for Medicare & Medicaid Services (CMS) released a proposed decision in which the agency suggested covering power seat elevation on Group 3 power wheelchairs. (For details, click HERE.) 

That proposed decision announcement started another public comment period that goes through March 17.

My first thought: I’m so happy for the industry. For you. I know this has been a long fight. When Mobility Management launched in 2002, I heard over and over how powered seating/wheelchair manufacturers and suppliers “gave away” seat elevation at little or no cost to the insurance provider or the consumer. Clinicians knew the many functional benefits of seat elevation, but CMS’s refusal to fund it meant that many industry professionals had a resigned attitude toward funding. I heard, “You eat the cost because of the benefit for the consumer.”

But even back then, everyone involved (except insurance companies and CMS) knew this was not a sustainable answer. Seat elevation provides positioning critical to mobility-related activities of daily living (MRADLs). It deserved to be funded.

So congratulations to everyone who kept fighting — who kept researching and gathering data, who continued to document functional benefits and improved outcomes, who talked again and again with CMS, other funding sources, and policy makers. Great work. And great patience, resourcefulness, and persistence, too.

My second thought: CMS got the message on seat elevation facilitating safer, more efficient transfers. CMS read the research provided by the industry, and seemingly looked for additional studies as well. CMS recognized the incredible strain placed on upper and lower extremities during transfers, and acknowledged the particular difficulty of transferring between surfaces of uneven heights, often referred to as “transferring uphill” in casual conversation.

Hooray for safer, more efficient transfers!

But my third thought: Could CMS’s laser focus on transfers inadvertently leave some power wheelchair users behind?

The proposed decision really, really focuses on transfers as the justification for seat elevation. I read a number of original public comments, and those comments also mentioned how seat elevation facilitates safer, more efficient MRADLs, such as reaching a stovetop, elevated freezer, or higher shelves in the pantry or bedroom closet.

I know CMS only provides Medicare funding for in-the-home activities, so I understand why CMS wouldn’t consider seat elevation uses such as “Makes power chair user more visible to car traffic when crossing streets,” or “Enables power chair user to reach higher shelves at the supermarket.”

And I understand that while there are many social and emotional benefits of being eye to eye with peers, that isn’t necessarily a seat elevation function that CMS considers medically necessary.

But elevating to see into a pot of hot soup on the stove while stirring it? That’s definitely an in-the-home MRADL. So is elevating to reach clothes in a closet or to reach across or into a bathroom or kitchen sink.

If weight-bearing, active transfers using upper or lower extremities is the only medical justification for seat elevation, would that leave behind people who operate power chairs, but are dependent for transfers? I’m thinking of people with very high-level spinal cord injuries, for example. Or people with advanced ALS, though as a clinician friend pointed out, those folks would most likely be qualified for seat elevation while they were still capable of assisting in their transfers.

Since spinal cord injuries and ALS were among the many diagnoses mentioned in the proposed decision, I’m not thinking that CMS intended to exclude wheelchair users who rely on dependent transfers. But in my comments, I’m going to explain the importance of seat elevation in dependent transfers… the process is still safer and more efficient for both wheelchair user and caregiver if the seat height can be adjusted. And I’ll talk about seat elevation’s value beyond transferring.

I’ve heard from sources-in-the-know that industry clinicians and policy experts are working to provide detailed recommendations for CMS regarding additional functions of seat elevation.

So I’ll keep my comment simple. I’ll mention MRADL uses for seat elevation, and therefore encourage an expansion of their proposed coverage.

And I’ll thank CMS for expanding coverage of a powered seating function that will make such a difference to so many power chair users and their families.