woman in a wheelchair in the kitchen using the standing wheelchair technology to use the microwave

Step 1:

Advocate for Coverage

Medicare wants to hear from YOU! 

Aug. 16, 2022 UPDATE:

Comment Period Opens on Power Seat Elevation Systems; Review of Power Standing Systems Delayed
 

**YOUR COMMENTS ARE NEEDED BY SEPT. 14! **

CMS has opened a 30-day comment period on Medicare coverage of power seat elevation systems in power wheelchairs. The ITEM Coalition strongly encourages all advocates and organizations to offer robust comments in support of coverage before Sept. 14, 2022. 

Unfortunately, CMS also announced it is delaying review of Medicare coverage for power standing systems to a later date. ITEM is seriously concerned and disappointed with this decision and implores CMS to open an analysis of power standing systems at the earliest possible opportunity.

We are working with CMS to make this happen, but still need your help! The immediate need is for public comments in support of power seat elevation coverage by the Sept. 14 deadline, though we encourage advocates to include their support for power standing systems in their comments as well. When a separate comment period is opened for power standing systems, we will ask individuals to submit comments again focused on those systems only. 

Please use the tools and instructions below to submit your comments today! 

The Medicare program currently prohibits coverage for seat elevation and standing systems in power wheelchairs and views these systems as “not primarily medical in nature.” They view these functions as “convenience” or “luxury” items for wheelchair users - we disagree.

People who use a wheelchair to navigate activities of daily living know how challenging it can be. It is vital to be able to:

  • Safely transfer from a wheelchair to another surface, particularly if it is not level with their chair;

  • Function independently at home as much as possible;

  • Improve circulation, bone strength, and skin health, along with other medical benefits when spending long periods of time in a wheelchair.

Medicare is currently accepting public comments about whether to cover seat elevation systems for Medicare beneficiaries. We encourage you to share your views with the Medicare program and let them know why it is important to provide access to these technologies.

What can you do?

The agency needs to hear why you support this coverage, in your own words, from your perspective! 

happy man standing outside with the assistance of a wheelchair power system
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CONSUMERS: People who use a wheelchair of any kind

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CAREGIVERS: Caregivers, friends or relatives of a person who uses a wheelchair

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CLINICIANS: Healthcare providers that serve patients who use wheelchairs

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MANUFACTURERS or PROVIDERS: Anyone who works with wheelchair technology

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ORGANIZATIONS: Groups that represent people who use wheelchairs, health care providers, or other disability advocates

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GENERAL PUBLIC: Anyone who supports access to wheelchair technology for people with mobility disabilities

When commenting, consider the following information to explain your unique story.

Medicare must receive individualized comments with your unique voice, so please use your own words and explain why you support coverage of seat elevation and standing systems.

 

The following are suggested talking points that you can use to form your letter, but make sure to personalize these comments and include any additional information that supports your position.

Talking Points for Comments

If you would like to view these talking points as a separate PDF which you can print out, click on the icon.

Identify Yourself

Provide a brief introduction of who you are and why you support this coverage. It’s important to provide your specific perspective and explain why YOU are supporting coverage for seat elevation and/or standing systems.

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  • Talk about why you are connected to this issue and why it matters to you. 

  • Do you use standing or seat elevation yourself, or do you know or care for someone who uses these systems? For how long? How have you found that these systems help you be healthier or function more independently within your home? Are there injuries you have avoided due to the use of standing or seat elevation?

  • Are you a physician or other health care provider serving wheelchair users? What are your areas of expertise, and what kind of patients do you usually treat? Do you prescribe seat elevation or standing systems? For what type of patients are these systems most effective?

  • Do you work with an organization that serves wheelchair users or represents other interests in the disability field? What organization do you represent, and what kind of work do you do? Why is your organization interested in and supportive of this effort?

    • IMPORTANT: Are you submitting on behalf of your organization as a whole, or as an individual working for that organization? Either is helpful, but please make sure to clarify who you are speaking for.

  • How are you/your patients able to access seat elevation or standing systems? Did your health plan provide coverage, or did you have to pay out of pocket? Did you encounter any barriers to accessing these systems?

  • If you do not use seat elevation or standing, do you know people who do? Would you benefit from using these features yourself? Are you able to achieve the benefits of standing through other means?

  • EXAMPLE: I am a wheelchair user and have used a power wheelchair for the past 20 years of my life. In the past four years I have benefitted greatly from having an elevating seat in my wheelchair. I count myself lucky to have this technology because it has changed my life.

Express Your Support

State clearly that you believe Medicare should extend coverage of seat elevation and standing systems in power wheelchairs for Medicare beneficiaries with mobility disabilities.

Mention the Health Benefits

Note the numerous health benefits of these systems, especially any benefits that you have experienced or seen.

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  • Talk about how seat elevators or standing systems have impacted you or someone you know! 

  • Some health benefits of these systems include:

    • Avoiding muscle strains, muscle spasms, arthritis, and/or nerve problems.

    • Decreased risk of falls when transferring,

    • Reduced neck strain when raising your line of eyesight,

    • Improved joint mobility, bladder function, and muscle strength when standing,

    • Improved heart and lung function,

    • Increased bone health.

  • If you have expertise on the clinical research area, it is very important to cite any clinical literature or other evidence to support the benefits of these systems. For more information on the evidence the ITEM Coalition has identified, please visit our Resources page, especially the proposed National Coverage Determination request.

  • EXAMPLE: Since I began using power standing, I have been able to avoid pressure sores and muscle contractures that I used to experience before I had access to standing. This has helped improve my overall health in a major way and has reduced my need for additional medical care related to my wheelchair use. 

Talk About the Functional Benefits

Note the numerous functional benefits of these systems, especially any benefits that you have experienced or seen.

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  • Talk about specific examples of the benefits of these systems in daily life. 

  • Functional benefits of these systems may include:

    • Safer/easier transfers from a wheelchair to a bed, chair, or toilet,

    • Easier access to reaching shelves, cabinets, freezers, or other areas,

    • Safer/easier performance of daily activities in the home, such as cooking, eating, and toileting,

    • Any other tasks in the home that these technologies allow users to perform, whether more easily/independently or something they would not be able to do otherwise.

      • Be sure to stress activities performed in the home, rather than in the community or other settings. This is because of Medicare's "in the home" requirement.​

  • EXAMPLE: My life has greatly improved thanks to my seat elevator. I am now more independent than ever. I no longer need a personal care attendant to cook for me, because I am able to reach my stovetop, the upper shelves in my refrigerator, and the food in my cupboards. This may sound simple to you, but for most of my life before seat elevation, I could not do this simple task on my own, simply because I could not reach. I am so thankful that I can now perform important daily activities in my home, thanks to the seat elevator. 

Conclude

  • Thank Medicare for the opportunity to submit comments and restate your support for coverage.

  • Encourage Medicare to quickly approve coverage of seat elevation and standing systems to ensure that wheelchair users can access the care they need.

  • Make it personal! What you say matters and your unique perspective is important. 

  • EXAMPLE: I shouldn't have to count myself lucky to have this technology. Seat elevation and standing systems bring wheelchair users to a level playing field with nondisabled people. With this technology, wheelchair users like myself can finally access things that nondisabled people take for granted, and we can be healthier, more independent, and have a better quality of life. Everyone who has a medical need for seat elevation and standing system should be able to have this technology covered, not just the lucky ones who can pay out of pocket. Please approve Medicare coverage for seat elevation and standing systems TODAY!  

Click on the arrows below to read more about each point.

Here is how to contact CMS:

Click the button below to submit your comments and to share your views on this coverage with Medicare:

Click on the CMS PHI Posting Policy link and then check the box that reads: “I have read and understood the CMS policy regarding redaction of PHI.”

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Tell your story as you wish, and this will protect your privacy. Then, fill in your information in the boxes marked with an asterisk. In the comment field, please type in your message using the talking points as a guide if they are helpful to you. Medicare wants to hear YOUR story, and public participation makes all the difference.

Please do not just copy and paste the information above into the comment box. Medicare will disregard these types of comments.

If you would like to see some examples of comments written by different people, see below.

Take all 3 steps to show your support!

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