By Allison Fracchia


Editor's note: Allison Fracchia, a physical therapist and coordinator for Methodist Rehab's Assistive Technology Clinic, penned the following letter to urge members of congress to support a separate benefit category for complex rehab technology. 

Dear Member of Congress,

I am a Physical Therapist who has 17 years of experience working with people who have long term permanent disabilities. My primary role is to provide complex rehab technology services including evaluation, trial, specification, fitting, and training for individuals who need specialized seating and wheeled mobility systems. I work at Methodist Rehabilitation Center in Jackson, MS which is the largest comprehensive rehabilitation center in the state of Mississippi. It serves a variety of individuals with complex orthopedic and neurological problems and specializes in serving people who have had a stroke, spinal, or brain injury.

MRC is renowned for its dedication to neurological rehabilitation research. Our outpatient Assistive Technology Clinic serves approximately 400 people annually. Most of our patients have a variety of diagnoses from rare neurological and congenital diseases to catastrophic traumatic injuries.These individuals deal with physical, functional and cognitive challenges every day and utilize Complex Rehab Technology to maximize their function and minimize the extent and costs of their medical care.

Unfortunately over the past several years I have seen a decline in people being able to receive seating and wheeled mobility products that they need in order to prevent medical complications from occurring (e.g. pressure sores) or to maintain/ improve their quality of life. This decline is due to funding restrictions that stem from coding, coverage, and payment problems.

Presently individuals with disabilities are experiencing limited, reduced or denied access to Complex Rehab Technology (CRT) within the Medicare program. Medicare policy by design is geared towards the primary Medicare population of individuals with chronic disease over the age of 65. However, Medicare policy also serves the smaller population of individuals who qualify for Medicare due to permanent disability. This policy strongly influences Medicaid and private third party payer policies thus impacting virtually all individuals with disabilities.

Access to Complex Rehab Technology is threatened because of its inclusion in Medicare's outdated classification system for durable medical equipment (DME). The DME benefit was created over forty years ago to address the medical equipment needs of elderly individuals. Over the years available technology has advanced yet Medicare policy has not kept pace.

Complex Rehab Technologies and services are by nature very different from Durable Medical Equipment, yet they are grouped together with one set of coverage, coding and payment policies. Countless long term attempts with CMS and CMS Contractors to address DME coding, coverage and payment policies over the past decade have been ineffective.Therefore a new CRT benefit category is proposed that permits segmenting of technologies (CRT and DME) and populations (acute and/or chronic diseases versus permanent disability). This will allow for a much more targeted approach for policy designed around complex rehab
technologies and individuals with disabilities that will enable appropriate beneficiary access and program safeguards. Furthermore establishing a separate CRT benefit category will enable Congress to mandate the parameters of the CRT benefit program and direct CMS in its implementation.

Overall, a new CRT benefit category offers an opportunity to comprehensively overhaul the benefit and create coordinated coding, coverage and payment policies that promise to improve access to CRT for the individuals who need it.

Precedence exists for treating customized devices differently. Congress has acknowledged complex rehab power wheelchairs are unique and more specialized than standard DME. In 2008, it passed legislation exempting these products from inclusion in the planned Medicare DME competitive bidding program recognizing that such inclusion would jeopardize access to this customized technology. In addition, CMS has recognized the unique nature of other customized products and services and created a separate and distinct classification for Orthotics and
Prosthetics (O&P). CMS acknowledged the specialized service component inherent in custom-fit orthotics and prosthetics and treats O&P as separate and unique with its own Medical Policies, Accreditation Standards, and Reimbursement Calculation.

Please help improve consumer access to complex rehab technology by supporting legislation for having a Separate Medicare Benefit Category for CRT products. If you would like to further discuss this topic feel free to contact me.

Allison Fracchia PT, SMS
Methodist Rehabilitation Center, Jackson MS
Assistive Technology Clinic Coordinator