Clinicians worry CMS policy shift could undermine CRT decisions

MINNEAPOLIS – The Clinician Task Force has concerns with CMS’s decision to no longer require a face-to-face evaluation for identical replacement power mobility devices (PMDs) at the five-year reasonable useful lifetime (RUL). 

The CTF calls the evaluation with a seating and mobility clinician at the five-year RUL “a safeguard” to ensure replacement equipment, particularly complex rehab technology (CRT), is still the most beneficial for the user. Without it, the organization says, clinical reasoning wrongly shifts to suppliers. 

“To say it is not necessary is to, sadly, open the door for those who are under pressure to get orders in and for those who see this as a way around the paperwork,” said Tamara Kittelson, executive director of the CTF. “We feel like this clinical piece needs to stay there.” 

The CTF recently sent a letter expressing its concerns to not only CMS but also to other CRT-affiliated organizations like NCART, iNRRTS and RESNA. 

In addition to reducing safeguards, the CTF makes the case that eliminating the evaluation discounts: 

• The variety of products within a code. “You can have two or three things with the same code, and they all have a different function, like foot straps and shoe holders,” Kittelson said. 
• The potential advancements in technology over any five-year period. “What you had was good, but now there is this new thing available that would make your life so much better and you want to be able to offer those options, as well,” she said.   
• The progression of a user’s condition over any five-year period – something that requires a reassessment, she said. 

In its letter, the CTF recommends that CMS update the policy to require evaluations as standard care for equipment replacement, even when identical codes are requested. 

In a nod to administrative burdens, however, the organization also suggests the agency modify the policy to accept reduced clinical documentation at the five-year RUL with an assessment from a clinician with an ATP or ATP-SMS certification. 

“Believe me, we’d like to lessen the paperwork,” Kittelson said. 

This is an important point, says Dan Fedor, director of reimbursement and education for U.S. Rehab. He stands by the policy change in general but agrees that CMS should consider requiring a licensed certified medical professional (LCMP) to attest they’ve seen a patient at the five-year RUL for CRT and they’ve confirmed the equipment needed is identical. If there are any changes, they should document the medical necessity for those changes.  

“But they shouldn’t have to re-justify identical items,” he said. “Prior to June 2, they had to re-justify identical items – the power base, the tilt and recline, etc. All technical requirements also had to be met (dating sequence, concurrence). That is unnecessary if it's determined that the replacement PMD is identical. They don't want to, nor should they have to, redo that documentation.”