The Centers for Medicare & Medicaid Services (CMS) has opened a 30-day public comment period for Medicare funding of seat elevation systems used on Group 3 power wheelchairs.

In an Aug. 14 announcement, CMS said it will consider “the provision of both benefit category and coverage of seat elevation systems in association with Group 3 power wheelchairs through the National Coverage Determination [NCD] process at this time.” Medicare currently doesn’t cover seat elevation “because it has not been determined that their use is primarily medical in nature.

“Medicare requires that DME [durable medical equipment] primarily and customarily be used to serve a medical purpose and to make a meaningful contribution to the treatment of the individual’s illness or injury or to the improvement of his or her malformed body member, when used in the home.”

The announcement added that the national coverage analysis would determine “if the use of power seat elevation systems in association with Group 3 power wheelchairs for the purpose of performing non-level transfers is a medical function that would, in conjunction with other factors and considerations, allow a benefit category and coverage determination for these systems.”

During the public comment period, CMS stated it is “specifically interested in scientific literature that provides evidence of the medical necessity of seat elevation systems by studying the measurable characteristics related to the performance of transfers.”

Public Comments Accepted Through Sept. 14

In an Aug. 16 update on the start of the public comment period, NCART said, “This is good news, and we have been anxiously awaiting this announcement. Now is the time for all CRT advocates to submit their comments supporting the request for coverage of power seat elevation systems during the public comment period, which ends September 14.”

NCART directed advocates to a Web site created by the ITEM Coalition, among the industry organizations leading the charge for seat elevation coverage. Advocates can send their comments to CMS by visiting www.rise4access.org. Visitors to the Web site can also sign a petition to support Medicare coverage for power seat elevation and power standing.

NCART’s message asked industry members to share the comment period information with colleagues and other interested individuals.

Power Standing Excluded from Comment Period

Complex Rehab Technology (CRT) stakeholders had simultaneously asked for coverage consideration for power standing systems on Group 3 power chairs, but CMS’s comment period excludes standing.

“The benefit category and coverage of standing systems will be considered at a later date,” CMS said in the Aug. 14 announcement, without offering a timeline.

In its Aug. 16 e-mail, NCART said it was “extremely disappointed” by the CMS decision to delay consideration for power standing, “since power standing systems were included as a connected benefit in the initial September 2020 request for coverage.”

The ITEM Coalition said in an Aug. 16 response that it is “seriously concerned and disappointed with CMS’s decision to delay the consideration of evidence for power standing systems, which were included as a connected benefit in the original September 2020 Request for Reconsideration of the National Coverage Determination for Mobility Assistive Equipment. After nearly two years of waiting for this NCA [National Coverage Analysis] to be opened, it is unacceptable that CMS has taken this course of action, and the ITEM Coalition implores CMS to open an NCA for power standing systems at the earliest possible opportunity.”

Tom Ryan, President/CEO of the American Association for Homecare (AAHomecare), said in an Aug. 16 statement, “While AAHomecare and mobility stakeholders are pleased to see the seat elevation NCD opened, we remain committed to the belief that both power seat elevation and standing systems deserve to be evaluated — and covered — in a timely fashion. We are disappointed that CMS has delayed the NCD for standing systems and urge CMS to expedite consideration for power standing systems as soon possible. Medicare beneficiaries with significant disabilities and their caregivers shouldn’t have to continue to wait for full access to these proven, life-enhancing products.”