I suspect I know what you thought upon learning that the DME MACs — Noridian Healthcare Solutions (Jurisdictions A and D) and CGS Administrators (Jurisdictions B and C) — said in their proposed local coverage determinations (LCDs) that power seat elevation on Group 2 power chairs is “not reasonable and necessary.”
I know what I thought, anyway.
I’ve been covering the Complex Rehab Technology (CRT) industry for 24 years. While I’m not a clinician, Assistive Technology Professional (ATP), rehabilitation engineer or policy/funding expert, I work hard to understand seating and wheeled mobility as thoroughly as I can.
But when I saw that announcement from CGS on Feb. 19 — the notice of proposed LCDs for power mobility devices and wheelchair options/accessories — I thought, please, let me be wrong.
I wasn’t.
Within minutes of my questioning email, Julie Piriano, PT, ATP/SMS, senior director of payer relations & regulatory affairs for the National Coalition for Assistive & Rehab Technology (NCART), confirmed my interpretation. The DME MACs had indeed proposed denying seat elevation for Group 2 power chairs as not reasonable and necessary via new LCDs.
The DME MACs also announced a March 25 open meeting to discuss the proposed LCDs. The comment period is already open and runs through April 4.
Julie’s first response was immensely important: While stakeholders are likely having strong feelings about this, responding with panic or anger could harm industry efforts.
So after some box breathing — inhale four seconds, hold four seconds, exhale four seconds, pause four seconds — I reflected on four truths.
1. We’ve been here before.
In November 2023, industry leaders — including Julie; Bill Ammer, Ammer Consulting; Brad Peterson, Amylior; and Peter Thomas (ITEM Coalition/ Powers Pyles Sutter & Verville) — presented seat elevation comments during the Centers for Medicare & Medicaid Services (CMS) second biannual HCPCS Coding Cycle Public Meeting.
Prior to that, CMS reported receiving 3,601 submissions during seat elevation’s public comment period in the summer of 2022. In May 2023, CMS announced it would cover power seat elevation on Medicare-covered power wheelchairs for eligible beneficiaries.
The comments, the meetings, the industry speaking in a unified, evidence-backed voice — we’ve done this before and seen success. Yes, we’re back at a crossroads — this time for Group 2 — when seat elevation has seemingly been in our rear-view mirror for nearly three years.
But the bigger takeaway is this: The industry has successfully organized around seat elevation before by leading with evidence of what optimal positioning can achieve. We can do so again.
2. We know seat elevation works.
Clients using Group 2 power chairs typically do not have the progressive/degenerative neuromuscular diseases, congenital disorders or injuries/trauma that NCART cites in describing who usually uses CRT.
But in explaining its decision to cover seat elevation on complex Group 3 power chairs, CMS focused on seat elevation’s ability to support non-level sitting transfers and sit-to-stand transfers.
Additionally, clinicians noted seat elevation’s ability to reduce the need to reach upward while performing activities of daily living — repetitive movements that can injure the shoulders, arms and neck. They also discussed seat elevation’s ability to improve positioning so that a power chair rider making a meal, for example, can rise, look into a pot on the stove, and cook more safely than would be possible at typical seated height.
Group 2 power chair riders may not have the conditions that qualify them for Group 3 power chairs. But they still need the functionality that seat elevation provides.
3. The industry is responding.
On March 19, Mobility Management will host an NCART-led webinar — Proposed PMD LCD Changes: Issues, Impact, and Industry Strategy — reviewing what the proposed LCDs say and how they compare to the national coverage determination (NCD); which power chairs and codes would and would not be affected; the clinical and functional benefits of power seat elevation on Group 2 power chairs; how the industry is responding; and the most effective ways for stakeholders to provide feedback and support.
The hour-long webinar begins at 2 p.m. Eastern, with Julie Piriano delivering the main presentation. We’ll leave ample time for Q&A. Registration is free for all stakeholders.
Register for access to the live event and to the recording afterward.
4. We know what we have to do.
While there are challenges to being a small, specialized health care segment, there are also advantages — and I saw that in real time after the DME MACs’ announcement.
I reached out to policy, funding and coding experts for comment, and their replies were swift and consistent: Before we respond, we must fully understand the situation. We will work with other industry experts and organizations to create a unified plan and response.
Undeniably, there are moments that make us want to shriek into the void.
But because our industry is small yet mighty, specialized yet essential, we’ve developed muscle memory for times like these. We prepare to move forward again, because “The best way out is always through,” as poet Robert Frost wrote.
Challenges can make us feel helpless. But we are not helpless. And we will not be immobile.
Register for the webinar and bring your questions. Share the registration link with colleagues. Register for the public meeting, and let’s show up in strong numbers — organized, professional and ready.
Friends, let’s gear up.
