Comments Due to CMS On Funding AAC Devices By Friday May 29!
On April 29, CMS released for review and comment a proposed revised National Coverage Decision (NCD) for Speech Generating Devices. A copy of the proposal can be reviewed by clicking here.
COMMENTS MUST BE SUBMITTED BY THE END OF FRIDAY, MAY 29.
This is just a DRAFT - CMS needs to hear from AAC stakeholders, just as 2300+ of us commented last fall and made CMS "stand up and take notice"! We must tell Medicare that we want the draft to be made a final guideline and we want it done as soon as possible. The changes that were made to Medicare SGD coverage in 2014 are causing harm and will continue to do so until a new NCD is effective.
- The draft NCD is very good and we want to thank Medicare staff for addressing the most important concerns that had arisen in 2014 regarding Medicare SGD coverage;
- The expansion of the definition of "speech" to include communication by texting, e-mail and phone is a very positive development;
- The recognition that SGDs’ non-communication capabilities and features can be made available, even though non-covered by Medicare, is a very positive development, and the procedure to - access these capabilities and features – use of an ABN form – will be easily adopted and easy to follow;
- It is essential that Medicare adopt a final revised NCD for SGDs as soon as possible. Until that occurs, the positive changes stated in the draft will not be implemented and there will continue to be confusion and harm to beneficiaries and their families from the policy changes made in 2014.
Although Medicare did not address ‘capped rental’ or ‘eye tracking accessories’ in the draft revised NCD, it is essential that both topics be resolved as soon as possible.
You also may wish to ask for clarification of terminology.
The proposed revised NCD is a terrific document. But it is only a draft. To help it become a final guideline, members of the AAC community are urged as strongly as possible to submit comments to CMS that address these 5 or 6 points. If you have personal knowledge of harm experienced by a Medicare beneficiary or his or her family, please include that in the comment related to the urgency of issuing this revised NCD as a final guideline as soon as possible.
Medicare provides a way to submit comments electronically. They can be prepared in a word-processing format then copied onto the Medicare comments template found by clicking here.
Note regarding entering comments:
Anyone with questions about the draft NCD or how to submit comments can contact Lewis Golinker at firstname.lastname@example.org.
Recreational Therapists Practice Act
PSHA is supporting the “Recreational Therapists Practice Act” (HB 2290) that was introduced this past May. This act requires all recreational therapists (RTs) in Pennsylvania (PA) to be licensed (which will require all RTs in PA to be nationally certified). This is needed to ensure the safety of the citizens in PA. There are approximately 1,600 RTs in PA, but only half are nationally certified. This means that approximately 800 people are calling themselves RTs, and practicing as RTs in the state of PA who do not possess the basic credentials to do so. This is a major safety concern, and one that our organization fully supports.
To help get this bill passed, we need people who live in PA to contact their Representatives and ask them to co-sponsor the bill. This is super easy to do and takes less than 5 minutes. Simply go tohttp://www.legis.state.pa.us/cfdocs/legis/home/findyourlegislator/ and enter your zip code. Click on the person’s name who is listed next to “PA House” (this is your Representative). It will take you to the Representative’s home page. Look for the “contact” button and then cut and paste the below message into the email….it's that simple!
Dear [insert Rep’s name],
The “Recreational Therapists Practice Act” (HB 2290) was introduced this past May. This act requires all recreational therapists (RTs) in Pennsylvania (PA) to be licensed (which will require all RTs in PA to be nationally certified). This is needed to ensure the safety of the citizens in PA. There are approximately 1,600 RTs in PA, but only half are nationally certified. This means that approximately 800 people are calling themselves RTs, and practicing as RTs in the state of PA who do not possess the basic credentials to do so. This is a major safety concern. Would you want your loved one receiving RT by someone who is not qualified to do so? I certainly would not! I’m asking that you please co-sponsoring HB 2290 to ensure the safety of our citizens.
[insert your name]
After you contact your Representative, please send an email to Dr. Heather Porter and let her know whom you contacted (email@example.com). She is the Chair of the RT Licensure Committee for PA and is keeping track of everyone who was contacted. PLEASE ask all of your friends and family to contact their Representatives, too. Post this message on your Facebook page and make copies of it and give it out to people that you know (e.g., your baseball team, your clients).
Together, we can make a difference in healthcare! Thank you for your help with this. I REALLY appreciate it.
Talking Points for the CMS Changes for Funding Speech Generating Devices
Medicare substantially changed its Speech Generating Devices (SGD) coverage policy to completely prohibit SGDs from having any non-speech capabilities, and from ever being modified or upgraded to include “non-dedicated” features, even when that modification or upgrade is paid for by the Medicare beneficiary. This policy change did not result from any findings by Medicare of problems with the SGD benefit. There is no SGD supplier fraud, or overuse (the maximum number of SGDs ever purchased by Medicare in any year is about 3,000 devices), or misuse of SGDs by any Medicare recipients.
- The absence of issues regarding SGDs is directly related to the procedures stated in the 2001 Medicare SGD coverage guidance. Medicare directed speech language pathologists (SLPs) to conduct a formal assessment of recipients, the outcomes of which are identification of SGD need and recommendation of the specific SGD and any necessary accessories. Then, the recipients’ physician must review the SLP report and have a face-to-face encounter with recipients to support all SGD prescriptions.
- Prohibiting SGD upgrades is a policy change that will save Medicare no dollars yet will substantially harm the Medicare recipients who rely on these additional capabilities. Allowing them has never resulted in increased cost to Medicare. Like all upgrades, these capabilities are accessible at recipients’ expense. No requests ever were submitted for Medicare to pay for them, nor will prohibiting them save Medicare any money.
- The Centers for Medicaid and Medicare Services (CMS) have been provided with information substantiating the harmful impact of these changes on people with disabilities who require SGDs; CMS has indicated it will not change its decision.
- WHAT PSHA MEMBERS CAN DO: Ask your that Member of Congress to draft a letter and send it to the Secretary of the Department of Health and Human Services requesting SGDs be permitted to retain these capabilities, and the ability to modify or upgrade features after Medicare has purchased the device be allowed.
The Honorable Sylvia Mathews Burwell
Secretary of Health & Human Services
200 Independence Avenue, S.W.
Washington, D.C. 20201
Dear Secretary Burwell:
I have been contacted by some of my constituents concerning Medicare coverage for speech generating devices (SGDs). SGDs provide individuals who are unable to speak, use sign language, or write because of ALS, cerebral palsy, stroke or traumatic brain injury the ability to communicate and therefore lead safer and more productive lives.
Over a decade ago, Medicare adopted an SGD National Coverage Decision that established SGDs were covered by Medicare as items of durable medical equipment (DME). Most recently, Medicare substantially changed its SGD coverage policy to prohibit any SGD upgrades (device modifications to allow any capabilities beyond speech generation) for the life of the device and to refuse coverage of eye tracking accessories, both of great value to individuals with the most severe physical as well as severe communication impairments.
Prohibiting SGD upgrades denies the most severely physically disabled Medicare recipients with SGD needs access to capabilities that are of great importance to their autonomy, independence and safety, yet of no cost to Medicare. Denial of eye tracking accessories goes even farther: it denies Medicare recipients complete access to and the ability to benefit from their SGD, even for speech generation.
I would appreciate it if you would reevaluate these policy changes, and to reconsider the limitations on SGDs and SGD accessories that have been imposed. I specifically ask you to give consideration to the effects these policy changes have on Medicare recipients such as those with ALS.
Thank you for your prompt attention to this matter.
Pennsylvania General Assembly Information
Members of the State Assembly
Pennsylvania State Information by the American Speech Language-Hearing Association
Step 1: Include your address at the top of the letter.
Step 2: Identify your Legislator. Be sure to address the Legislator appropriately by using “The Honorable” in the address line and “Representative” or “Senator” in the salutation. A colon follows the Salutation.
Step 3: Introduce yourself. State your connection to the legislator. Identify if you are a constituent of the Legislator. The other characteristics are, “I am a taxpayer, citizen, and voter who resides in the ____________________ School District.”
Step 4: Note any relevant facts you wish the Legislator to consider.
Step 5: Let the Legislator know what you are asking for. For example, “I am requesting that the state use a portion of the Rainy Day Fund to support public education.” (Keep this to one or two points.)
(For Steps 4 & 5: You may use the Community Legislative Committee's Legislative Priorities, available on their website.)
Step 6: Thank the Legislator for his or her time and support. Close the letter with “Sincerely,” “Yours truly,” or “Respectfully.”
If you wish to contact others, please consider contacting the Chairs and/or the other members of the key committees: House and Senate Education Committee and the Senate Finance Committee.
Down Load Sample as a Word Document
Letter Writer’s Name
City, PA and Postal code
City, PA Postal Code
Dear Representative or Senator _______________,
I am writing you about ______________________. I know you share my commitment to _____________________. I have lived in your district for the past ___________ years. Through my work in _______________ area I see first-hand the need for _________________. I am convinced that ______________________ will help. I ask for your support regarding_______________________.
As a clinician, I recently ________________________ ( add a personal story if able here relating to your request.)
I understand that the ___________ committee will be hearing about the ___________________ bill this session. I urge you to support this measure when it comes before you. I would be happy at any time, to provide you with more examples of _______________. I hope we can count on your support. Thank you for your work on behalf of our district and the State of Pennsylvania.