Separate benefit for complex rehab: Let the discussions begin

Thursday, March 4, 2010

BUFFALO, N.Y. - When industry stakeholders gave an overview of a "discussion paper" that details a separate benefit for complex rehab during a Webinar last week, providers and therapists had a lot of questions. That's exactly the response stakeholders were hoping for.

"We've labeled it a discussion paper for a specific reason," said Don Clayback, executive director of NCART and chairman of a steering committee working to create the benefit. "It's meant for discussion. It's not a final plan; it's not a finished product; it's not something that's take-it-or-leave-it. It's meant to be circulated to allow people to respond."

The 24-page paper has been posted to NCART's Web site, It proposes changes to products and coding; coverage and documentation; payment; and supplier quality standards.

Highlights from the Webinar:

Products and coding

Current HCPCS codes, where appropriate, would be classified as complex rehab technology (CRT) and would be available only through accredited CRT companies; modifications would be made, as needed, to codes that currently contain both CRT products and non-CRT products to separate CRT from DME; and new codes would be added for CRT products that are routinely provided but currently don't have assigned codes.

"At the end of the day, there should be a fairly bright line," said Rita Hostak, vice president of government relations for Sunrise Medical and a member of the steering committee. "One line says, 'yup, this is clearly DME,' and one says, 'yup, this is complex rehab technology.'"

Coverage and determination

Coverage criteria would be based on a beneficiary's functional abilities and limitations, not specific diagnoses; the burden of clinical documentation would be shifted to the therapist's shoulders instead of the physician's; and the "in-the-home" restriction would be eliminated.


A payment methodology would be established that covers both the product costs and related service costs that are associated with CRT products. Avalere Health Group will help to determine the potential options and preferred methodology.

Supplier quality standards

Complex rehab technology companies would be required to offer service and repairs to beneficiaries in their sales area, either through their own operations or through another accredited company. For beneficiaries outside their sales area, they would have to make their best effort to locate another accredited company.

Also, the companies would be required to have at least one rehab technology professional (RTP) on staff. An RTP is an individual who has passed RESNA's ATP exam and has fulfilled "additional requirements." Those requirements may include obtaining RESNA's seating and mobility specialist (SMS) certification or an enhanced version of NRRTS's CRTS credential.

Stakeholders pointed out that work on these areas will continue through various working groups.

Questions were largely detail-oriented. For example: In rural areas where there are no seating clinics and few therapists, how would providers comply with the benefit?

"We realize the ideal situation may not be achievable in every instance, but we won't let that dissuade us from getting there, or as close as we can," Clayback said.

Stakeholders plan to collect feedback on the paper all of March. Providers and therapists can do that two ways: e-mail comments to or post comments to a new blog,