As Laurie Watanabe, editor of Mobility Management magazine, writes in her “Liberating Complex Rehab” column, an effort to secure a separate benefit for complex rehab technology seeks in essence to more accurately identify and define both the types of equipment used by severely involved seating & mobility clients, and the clinicians and suppliers conducting the evaluations, fittings, fabrications, adjustments, client training, and service/repair. This is part one of Watanabe’s column on why the separate benefit effort should be reversed.
There is danger in being labeled something you’re not — witness the 9.5-percent Medicare funding cut to the complex rehab power category after it was carved out of future Medicare competitive bidding programs.
#1: It’s time to stop comparing apples to oranges.
It’s an old, but entirely true argument: Complex rehab technology is different than DME.
“The big picture is that complex rehab technology is a small segment of the home medical equipment marketplace, and it is used by people who have in the majority of the cases very significant disabilities,” says Don Clayback, the new executive director of the National Coalition for Assistive and Rehab Technology.
“That’s why they need this kind of equipment.”
Complex rehab is currently considered merely a type or form of DME, which means its unique factors are often overlooked or not understood. Case in point: After intensive lobbying and education efforts from the industry, complex rehab power chairs and accessories were deemed inappropriate for Medicare competitive bidding and were thus carved out of future programs. Yet, when it was time to “pay for” a July 2008 postponement of the program, complex power was included in the 9.5-percent funding cut along with the rest of the product categories involved in the failed Round 1.
“What we see happening over the last few years,” Clayback says, “is because there’s really a lack of understanding of what’s involved in this from a payor perspective or a policy-maker perspective, there’s not the necessary appreciation of the complexity of the products, the service component of the delivery model and the costs that are incurred in that process. There’s not enough awareness of that, so consequently — whether it’s coverage changes or cutbacks or competitive bidding discussions — these products get included in there, and really they’re not appropriate based on those dimensions I mentioned.”
So if complex rehab technology is not DME, what is a good comparison? Possibly orthotics and prosthetics (O&P), Clayback says, “at least to communicate what we’re trying to accomplish.” He points out that O&P is “a separate category within the DME benefit. Orthotics and prosthetics are treated differently because they’re individual to the user of the equipment; they require evaluation, assembly and fitting; and they require ongoing support.”
#2: This lack of distinction is hurting complex rehab providers and consumers.
It’s easy for payors, referral sources, consumers and other stakeholders to contend that the separate benefit is largely about increasing funding for complex rehab. But the fact is that defining complex rehab as a slice of the larger DME pie ultimately hurts consumers. “When we see coverage changes or coverage limitations or when we see cutbacks, that’s eroding access to this technology,” Clayback says.
“From a supplier perspective, I think it’s well recognized that this segment isn’t a real attractive segment from a business perspective because it’s very service intensive, the profit margins are low, and the paperwork requirements are significant. From a pure business perspective, there’s a lot of challenges, which means there’s less companies that are remaining in this business. As those companies decrease, the patient access decreases. As those companies are forced to undergo ongoing reductions, they have to limit either product choice or limit services. They might not be able to continue to provide them under continued rate reductions.”
So, sure — providers’ businesses are being hurt. But ultimately, having fewer complex rehab businesses in existence will hurt the consumers who need the technology and all the expertise and service that goes along with it. Referral sources will also feel the frustration, if they have fewer qualified complex rehab professionals to call upon.
When it comes to the connection between funding problems and accessibility problems, Clayback explains, “I would say there’s a straight line — it’s not a dotted line, it’s not even a long line. If there is a reimbursement problem, that translates into an access problem. Or at least on the surface, immediately the access (question) should come up.
“When you look at complex rehab technology, we’ve done studies through NCART and there’s a variety of information that’s available. When you look at other segments in the market, the number of companies that provide complex rehab technology is very small, and that number is decreasing. So I can show you all kinds of financial reports and flow charts and all the steps that are involved, but this is a very difficult market to operate in, and I don’t think there’s any better evidence than to say, ‘Look at the few companies that are still operating in this business.’”
#3: This effort means no disrespect to DME.
Establishing a separate category for complex rehab isn’t a matter of having no respect for the existing DME benefit, but rather a matter of making sure complex rehab is defined and understood as accurately as possible.
“There definitely is a place for durable medical equipment,” Clayback says. “There’s definitely a place for respiratory equipment, so I think those are well-recognized product categories. What we’re saying is that when you start making decisions on coverage policy, payments, whatever, having these specialized (complex rehab) products lumped in with other categories presents some real access problems.”
#4: Complex rehab technology would finally be clearly defined.
Up until now, complex rehab technology has too often been defined in the eye of the beholder. Yes, Medicare made some inroads in separating consumer and complex rehab power chairs, but overall, it’s still an incomplete, overlapping and somewhat vague definition. For example, skin-protection and positioning wheelchair cushions were part of the recent Round 1 rebid as part of a category that Medicare calls Complex Rehabilitative Power Wheelchairs & Related Accessories — Group 2.
But with the new benefit category would come, finally, very specific definitions.
“We have clearly defined what complex rehab is,” Clayback says. “First, we started with more of a broad definition. We have crafted the definition so it isn’t just restricted to seating & mobility.”
In brief, Clayback says complex rehab would be defined as “an item that’s medically necessary, that’s configured to the individual and requires a combination of specific activities: evaluation, assembly, fitting, training, ongoing support.” The definition goes on to list the diagnoses of patients who typically use this type of equipment.
“Here’s the products, and here’s the people that use it,” Clayback says.
A more-detailed, two-page working definition includes what Clayback calls the “four Ps — the products that we’re talking about, the people who use it, the process that’s involved, and the professionals that are part of the delivery model.” The initial focus is on seating & mobility, plus “other adaptive equipment — standers, gait-trainers, other kinds of specialized equipment that fall under that definition.” But Clayback adds, “Speech-generating devices and other assistive communications devices would potentially fall under that. We’ve had some initial discussion with those groups, and they’re interested in this. They may become part of it or look to be involved down the road at some point.”
To identify the specific products that meet this new definition, Clayback says, “We’ve taken specific HCPCS codes — about 130 of them — that are either strictly complex rehab, or a significant part of that product code is complex rehab. One of the things we’d like to fix is for certain codes there’s an overlap: You have complex rehab products and standard mobility products. They both have a purpose and they both have a benefit, but for these specific HCPCS codes, you have to be an accredited complex rehab provider to provide them.”
#5: A seating & mobility client’s world should be made up of far more than four walls and a roof.
Once upon a time, the phrase “in the home” was used to distinguish durable medical equipment used in a Medicare beneficiary’s home from equipment used in a hospital or healthcare facility setting.
But that was a long time ago, and somewhere along the way, “in the home” morphed into a Centers for Medicare & Medicaid Services (CMS) restriction, one that perhaps inadvertently, but very effectively limited the definition of a Medicare beneficiary’s living spaces.
“We feel that, inappropriately, CMS interprets some of the language in the Social Security Act that says equipment is only covered in the home,” Clayback says. “We’re looking at eliminating that relative to complex rehab technology.
“If someone needs a power wheelchair, they should be able to access the necessary equipment, not just for their home needs, but also to get out into the community for their medical needs, social needs, educational, work and other needs. And really, our stated objective for this category is to improve and protect access for people with disabilities that need these products.”
Long the bane of complex rehab consumers, the in-the-home restriction might help stir consumer interest in the industry fight to establish a separate benefit category.
“The consumer is really the focus,” Clayback says, “and we’ve had some very productive discussions. I think this gives us the opportunity to have a stronger connection with consumer groups and have some frank discussions.” (Example: Paul Tobin, president of United Spinal Association, is a separate benefit category steering committee member.)
Discussions, Clayback adds, would concern how the status quo — complex rehab technology lumped in with DME, and dwindling numbers of complex rehab providers — is impacting consumers’ freedom of choice.
“If I’m a consumer…I want a company that’s got a good selection of products, that’s going to give me good customer service, and is going to be around if I need some sort of support,” he notes. “I think we all realize that for those companies to exist, the business environment has to be such that there’s appropriate coverage policies and payment rates.”
And speaking of payment rates: Next month, in part two of this column, we discuss three more reasons to support the separate benefit effort, including the role that funding will play, the need for new complex rehab technology provider standards, and the project’s various work groups, which are tackling this effort from several critical angles. Plus, we’ll share ways that you can get plugged in and help drive this meaningful effort.