To the delight of many longtime disability and mobility advocates, the Centers for Medicare and Medicaid Services (CMS) announced it is now officially considering power seat elevation systems used with Group 3 power wheelchairs for a benefit category and coverage through the National Coverage Determination process. A public comment period on seat elevation systems coverage is open until September 14.

While other payers cover seat elevation systems, Medicare does not because, according to CMS, “it has not been determined that their use is primarily medical in nature.”

The announcement reads, in part, “A power seat elevation system is a component of a wheelchair that raises and lowers users while they remain in the seated position, providing varying amounts of vertical height. Section 1861(n) of the Social Security Act specifically identifies wheelchairs as durable medical equipment (DME). Medicare requires (among other criteria) that DME primarily and customarily be used to serve a medical purpose and to make a meaningful contribution to the treatment of the individual’s illness or injury or to the improvement of his or her malformed body member, when used in the home.”

This process provides an opportunity to change the way CMS views seat elevation systems with regard to medical necessity. According to the CMS, “The purpose of this National Coverage Analysis is to determine if the use of power seat elevation systems in association with Group 3 power wheelchairs for the purpose of performing non-level transfers, is a medical function that would, in conjunction with other factors and considerations, allow a benefit category and coverage determination for these systems.”

CMS will consider standing systems separately at an as yet undetermined later date, according to the announcement. The explanation given was that considering these systems “requires the evaluation of two distinct groupings of evidence.” 

The expected completion date for the National Coverage Analysis of seat elevation systems is May 16, 2023. However, CMS is scheduled to provide information about the decision earlier than that, based on the posted due date of Feb. 15, 2023 for a proposed decision memo. 

Will you submit public comments? Do you think CMS should have evaluated standing systems along with seat elevation systems? Let us know in the comments below.