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Commentary: Location, Location, Location for MRADLs Is Crucial to Independence
On brushing teeth, the NCD and customary settings.

April 15, 2026 by Laurie Watanabe

In my 30s, I had major surgery and was hospitalized for more than a week. Internal bleeding, multiple blood transfusions, the works.

I was kept in bed the first two days. On the second day, a nurse brought me a dusty-rose-colored basin (you know the type), a cup of water, a toothbrush and toothpaste so I could brush my teeth in bed. The process felt vaguely disgusting.

When I was allowed out of bed on the third day, I dragged my IV pole to the bathroom and brushed my teeth at the sink. It took me an hour to get out of bed, walk to the bathroom 15 feet away, brush my teeth, and get back into bed.

That night, the nurse said I could brush my teeth in bed. But I plodded to the bathroom, muttering under my breath, “Only sick people brush their teeth in bed. I brush my teeth in the bathroom.”

For the rest of my hospital stay and in a related hospitalization years later, that remained my mantra: I brush my teeth in the bathroom.

I wasn’t sure why getting to the bathroom was so important to me until February, when Julie Piriano, PT, ATP/SMS, senior director, payor relations and regulatory affairs for the National Coalition for Assistive & Rehab Technology (NCART), mentioned in our Mobility Management webinar that the definition of mobility-related activities of daily living (MRADLs) includes these activities taking place in the home locations you’d expect.

The Centers for Medicare & Medicaid Services’ (CMS) national coverage determination (NCD) for mobility assistive equipment (MAE) — which includes canes, crutches, walkers, manual and power wheelchairs — says, “CMS finds that the evidence is adequate to determine that MAE is reasonable and necessary for beneficiaries who have a personal mobility deficit sufficient to impair their participation in mobility-related activities of daily living such as toileting, feeding, dressing, grooming, and bathing in customary locations within the home.”

The NCD doesn’t say, “As long as you’re able to brush your teeth somewhere, including in bed using a plastic basin, it’s all good.” The NCD says Medicare beneficiaries can expect to perform MRADLs in customary locations in their homes, and if they can’t, mobility equipment should bridge the gap, assuming it can be medically justified.

Medicare beneficiaries can expect to eat in the dining room. They can want to cook in the kitchen, and yes, brush their teeth in the bathroom. Eating breakfast in bed is fine, but only if you really want to eat there.

I now know “customary locations” has been in the NCD all along. I guess my brain typically focuses on the five MRADL categories rather than on location. Judging from responses we got after webinar, I’m not alone.

Brushing my teeth in a hospital bed made me feel “sick.” Laboriously brushing my teeth in the bathroom made me feel powerful.

Location, location, location, indeed.

The February webinar, Policy Innovation’s Impact on Seating and Wheeled Mobility Provision, also starring Theresa Berner, MOT, OTR/L, ATP, rehabilitation clinic manager for the Assistive Technology Center, The Ohio State University, and Tamara Kittelson, MS, OTR/L, ATP/SMS, executive director, Clinician Task Force, is available now on demand.

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