-------- Original Message --------
Subject: CMS (Medicare) SGD changes in payment
From: Alisa Brownlee <xxxxxx@alsa-national.org>
Date: Thu, February 13, 2014 3:18 pm
To: National ALS Association AT Listserv <xxxxxx@alsa.simplelists.com>

An important announcement from the ALS Association’s Public Policy Department

From: ALSA Advocacy [mailto:xxxxxx@alsa-national.org]

MEMORANDUM

DATE:     February 12, 2014

TO:         Executive Directors and Public Policy Chairs

FROM:    Steve Gibson, Chief Public Policy Officer

RE:          Capped Rental Update

Dear Executive Directors and Public Policy Chairs,

As you may recall from our alerts in August and September, the Centers for Medicare and Medicaid Services (CMS) has proposed to change the manner in which Medicare pays for speech generating devices (SGD) and certain wheelchair accessories. The change, which requires that patients rent these devices instead of purchase them, is scheduled to take effect on April 1, 2014.

If implemented, the change in reimbursement policy may negatively impact patients as well as Chapter loan closets. This may include patients losing coverage for and access to SGDs and wheelchair accessories and reduced donations of this equipment to Chapter loan closets. Please see the summary below for additional details about the change in reimbursement policy and potential impacts.

Current Status

The Public Policy Department has been actively engaged on this issue since CMS first proposed the change in reimbursement policy last July. We submitted formal comments to CMS (attached) expressing our concerns and opposition to the change. We also are actively working with a coalition of other organizations who share our concerns, including the National Coalition for Assistive and Rehab Technology (NCART), AAHomecare, United Spinal and specific companies, such as Dynavox, Numotion, Permobil, Pride Mobility, and Tobii ATI.

Most recently, Members of Congress, led by Senators Charles Schumer (D-NY) and Thad Cochran (R-MS) and Representatives Jim Sensenbrenner (R-WI) and Joe Crowley (D-NY), plan to send a letter to CMS formally requesting that the Agency:

·          Delay the April 1, 2014 implementation date;

·          Update its policy to require use of current data in their classification process; and

·          Meet with stakeholders to review concerns and recommendations.

We will continue to actively work to address our concerns about this policy and will continue to partner with other organizations as we explore all potential options to ensure that patients have timely access to this needed equipment.   We will keep you updated as the regulatory process moves forward and will let you know if there are any action items for Chapters.

In the meantime, we strongly encourage you to share this information with your Care Services staff to keep them informed about this potentially significant change.   The Public Policy Department is working closely with the Care Services Department on this issue and we anticipate sharing additional information with Chapters, including to help you respond to patients and families and prepare for this change should implementation occur on April 1.

If you have any questions or would like additional information, please contact Pat Wildman in the Public Policy Department at xxxxxx@alsa-national.org.

Summary:

CMS has proposed to move SGDs and power wheelchair accessories from the routinely purchased payment category to the capped rental payment category. In making the change, CMS relied on an analysis of Medicare claims from over 27 years ago (July 1986 – July 1987). The policy would apply to patients who have any condition, not just ALS, that requires the use of these technologies. Currently, most all SGD’s and wheelchair accessories used by people with ALS are purchased by patients, with Medicare covering 80% of the costs. Under a capped rental system, patients are required to rent these items over a 13 month period, after which time the patient owns the equipment. Medicare pays 80% of the rental fee each month. If the patient passes away or no longer needs the equipment at any time during the rental period, the equipment is returned to the supplier.   The ALS Association’s concerns include:

·         Access: If a patient is institutionalized (extended hospital stay, hospice, nursing home) during the 13 month rental period, Medicare coverage for this equipment will cease. Potentially, this means that a patient either will have to pay out-of-pocket the full monthly rental costs in order to keep their SGD or wheelchair accessory, or the equipment will be returned to the supplier, leaving patients without access to needed equipment.   Moreover, if a patient loses access to equipment while they are institutionalized, the equipment will not immediately be returned to them upon discharge simply because of the time it will take to coordinate the return of the equipment. By contrast, under the current system, patients may keep this equipment when they are institutionalized as long as they own the equipment.

·         Cost: If a patient rents an SGD or wheelchair accessory for the full 13 month period, they will pay 5% more out-of-pocket than if they purchased the equipment up front.

·         Quality: Both SGDs and power wheelchairs are highly customized in order to meet the specific medical needs of individual people with ALS. When they are returned to a supplier, they cannot simply be supplied to the next patient. They must be readjusted and customized to fit the needs of the next patient. Therefore, under capped rental, suppliers do not have the same incentives to work with people with ALS or to fully customize these devices knowing that they may be returned to them.

·         Loan Closets: Families often donate equipment to Chapter loan closets or other PALS when their loved ones pass away or no longer need the equipment. Under capped rental, the equipment would be returned to the supplier, not donated to a Chapter or PALS, if the patient passed away during the rental period.

Public Policy Department

The ALS Association

1275 K Street, NW

Suite 250

Washington, DC 20005

Ph: 1-877-444-ALSA

Fax: 202-289-6801

Email: xxxxxx@alsa-national.org

Alisa

Alisa Brownlee, ATP

Assistive Technology Specialist

ALS (Lou Gehrig’s Disease) Association, National Office and Greater Philadelphia Chapter

Conference Chair, RESNA 2014 Convention

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