Dingell, Colleagues Express Concerns to CMS Regarding Complex Rehabilitation Technology Coverage

U.S. Representatives Debbie Dingell (D-MI-06), Brian Fitzpatrick (R-PA-01), and colleagues expressed concerns about significant gaps in Medicare's coverage and reimbursement framework for complex rehabilitation technology (CRT) - including customized power wheelchair systems - for beneficiaries living with serious physical and functional disabilities.

"Under current rules governing Medicare's Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) benefit for CRT equipment, a component part must have already failed or malfunctioned before Medicare will cover any servicing of the equipment - meaning that routine, scheduled maintenance designed to prevent failure is categorically excluded from reimbursement. This framework is counterproductive in two respects. First, it drives avoidable equipment failures: problems that could be identified and corrected through routine maintenance instead go unaddressed until they become acute. Second, it undermines beneficiaries' ability to plan," said the lawmakers.

The lawmakers continued: "A second, related problem concerns the fact that Medicare's coverage of repairs to customized power CRT equipment is conditioned on the beneficiary having a valid prescription on file dated within the prior twelve months. For beneficiaries who depend on power wheelchairs and similar equipment, this requirement creates an unnecessary and potentially harmful administrative obstacle."

In a letter to CMS Administrator Dr. Mehmet Oz, the lawmakers highlighted CMS's responsibility to the tens of thousands of Medicare beneficiaries each year who depend on complex rehabilitation technology to maintain their mobility and independence. The lawmakers encouraged prioritizing these reforms and maintaining an open discussion between offices.

A copy of the letter can be found HERE and below:

Dear Administrator Oz:

We write to raise concerns about significant gaps in Medicare's coverage and reimbursement framework for complex rehabilitation technology (CRT) - including customized power wheelchair systems - for beneficiaries living with serious physical and functional disabilities. Two issues in particular warrant the agency's attention: an outdated prescription renewal requirement that creates unnecessary administrative barriers to equipment repairs, and the absence of coverage for preventative maintenance on life-sustaining equipment. We urge the Centers for Medicare & Medicaid Services (CMS) to address both through regulatory action.

Lack of Coverage for Preventative Maintenance

Under current rules governing Medicare's Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) benefit for CRT equipment, a component part must have already failed or malfunctioned before Medicare will cover any servicing of the equipment - meaning that routine, scheduled maintenance designed to prevent failure is categorically excluded from reimbursement. This framework is counterproductive in two respects. First, it drives avoidable equipment failures: problems that could be identified and corrected through routine maintenance instead go unaddressed until they become acute. Second, it undermines beneficiaries' ability to plan.

Scheduled maintenance is predictable and can be arranged around a beneficiary's care needs and daily life. Waiting for damage to occur makes servicing logistically unpredictable for individuals who rely on this equipment for mobility and independence.

CMS has the regulatory authority to modernize this framework, and we urge the agency to provide flexibility to allow for coverage of preventative maintenance on CRT systems. Doing so would reduce equipment failures and improve quality of life for beneficiaries.

Prescription Renewal Requirement for CRT Repairs

A second, related problem concerns the fact that Medicare's coverage of repairs to customized power CRT equipment is conditioned on the beneficiary having a valid prescription on file dated within the prior twelve months. For beneficiaries who depend on power wheelchairs and similar equipment, this requirement creates an unnecessary and potentially harmful administrative obstacle.

By their nature, Medicare beneficiaries who qualify for customized power CRT equipment have severe, permanent medical conditions - such as spinal cord injury or cerebral palsy - for which the need for the equipment will not change over time. Requiring a prescription renewal as a precondition for repair coverage adds little clinical value for this population, and yet it can delay access to critical service when a component fails. Such delays carry real consequences for beneficiary health, function, and independence.

Importantly, the Social Security Act does not expressly mandate a twelve-month prescription renewal as a condition of repair coverage eligibility. We believe that CMS has regulatory authority to waive or modify this requirement. We urge the agency to do so without delay.

Conclusion

Each year, tens of thousands of Medicare beneficiaries depend on CRT systems and equipment to maintain their mobility and independence. Removing the prescription renewal barrier and providing coverage for preventative maintenance of CR equipment are targeted, achievable steps that would meaningfully improve care for this vulnerable population. We encourage CMS to prioritize both reforms and welcome the opportunity to discuss them further.

Please feel free to contact our offices with any questions. Thank you for your attention to this issue.