Feedback needed on proposed funding change for AAC devices & power wheelchair accessories

From ATIA (Assistive Technology Industry Association):

ATIA wants your story!

Dear AT Community,

We would like to make you aware that the Centers for Medicare and Medicaid Services (CMS) recently proposed changes in how Medicare pays for speech generating devices (SGDs)(AAC devices) and power wheelchair accessories, such as custom seats and tilt-recline systems. Specifically, CMS is proposing to move SGDs and wheelchair accessories from the routinely purchased payment category to the capped rental payment category requiring that patients rent these devices as opposed to purchasing them. 

Here's a message from the ALS Foundation:

"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 supplier of an SGD or wheelchair accessory can require that the equipment be returned, leaving patients without access to needed 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."

Your Voice Counts! We should all be concerned that the needs of people who use SGDs (AAC) are addressed in the final policy. Voice your concern to the Centers for Medicare and Medicaid Services to let them know how this threatens the quality of life of so many Americans. 

How can you make your voice heard? Write letters or comments and encourage others to write. Here are some examples of what to say:

1. Provide information on how important on-going, consistent, long-term access and use of SGDs are to your clients and customers. Provide specific examples and success stories.

2. Write about a family member, friend, or associate who would not be able to meet their daily communication needs without a SGD. Provide specific examples of how lack of a device interferes with getting daily needs met, intra-family communication, work-based, income earning activities, parenting, getting medical care, education, etc.

Be sure to emphasize that a person's need for a SGD is often permanent and life-long, not temporary.

Comments on this proposed policy change are due no later than 5PM EST, August 30, 2013. Comments must be submitted with the following index code:  CMS-1526-P.
Submit your comments to:
1. http://www.regulations.gov. Follow the ''Submit a comment'' instructions.

2. By regular mail to Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1526-P, P.O. Box 8010, Baltimore, MD 21244-8010.

To quote Lewis Golinker, Esq., "Of Medicare's 45 million beneficiaries, and billions of dollars of costs, picking on the 2700 or so people with the most severe communication impairments as a source of a few dollars in cost savings at the expense of their health, dignity and person-hood, seems an extremely poor choice." 

If you'd like to share your comments with us email them to info@atia.org  with the subject line: CMS Changes.