Seat Elevation Systems as an Accessory to Power Wheelchairs (Group 3)

Hi, I am Brittany Evans and I am an Occupational Therapy Student at St. Joseph's University located in Philadelphia, Pennsylvania. as a future clinician for wheelchair users, our job is to make our patients as functional and mobile as possible, and that includes standing up!

When patients are able to obtain power elevation, it increases their independence with all their occupations including their activities of daily living. In an article written by Kenyon et al. (2021), in pediatric patients "Stand-on-demand' revealed how participants perceived PWSDs as allowing children to stand whenever and wherever they wanted, thereby increasing participation." If you have the ability and more independence when completing a task, you are more willing to participate in said task which could be life changing, especially in pediatric patients. Regardless, more participation equals more success with their ADLs.

It's also incredibly frustrating for these patients knowing their limits aren't reachable when financial circumstances negate them, I strongly encourage CMS to change its antiquated policies related to these important products.

Kenyon, L. K., Harrison, K. A., Huettner, M. K., Johnson, S. J., & Miller, W. R. (2021). Stakeholder perspectives of pediatric powered wheelchair standing devices: a qualitative study. Developmental Medicine & Child Neurology, 63(8), 969–975. https://doi.org/10.1111/dmcn.14842

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Thank you for your proposed decision to cover seat elevation on Group 3 complex rehab technology wheelchairs.

Thank you also for asking whether seat elevation should be covered on Group 2 power chairs. Yes, indeed: A number of Group 2 power chair users could benefit from seat elevation while transferring and performing MRADLs in their homes.

I do agree with NCART's comments that also ask for coverage for Group 4 and Group 5 power wheelchairs, if the beneficiaries meet the required qualifications (including, in the case of Group 4 chairs, the need for more robust suspension). I do believe, though, that seat elevation design and mechanisms will probably be different on Group 2 chairs than on Groups 3, 4, and 5, which usually also feature other powered seating, such as tilt and recline. Therefore, I hope that CMS and its partners will recognize that one sort of seat elevation doesn't necessarily fit all power chair bases, and provide suitable coding and allowables accordingly, so no access is restricted when the beneficiaries do medically qualify for seat elevation on whatever power base their physicians and seating professionals/clinicians have deemed best.

I am so pleased that CMS so thoroughly studied the challenges of transfers. Thank you. I also hope CMS will consider other uses for seat elevation, including reaching safely across a stovetop when cooking in the home. Or reaching into the freezer to grab something to cook.

I also hope CMS will consider the value of seat elevation even for power chair users who rely on caregivers and patient lifts to transfer them. For these folks, being able to adjust the seat height prior to using a sling lift/hoyer lift will still provide a much safer and efficient transfer, even if the person being transferred does not weight bear on their extremities. People with ALS, muscular dystrophy, spinal muscular atrophy, high-level spinal cord injury (quadriplegia), etc., in many cases can independently operate the power chair using alternative driving controls, but need the help of caregivers and patient lifts for transfers. Please don't inadvertently exclude them by mandating that the only qualifying transfers are those involving weight bearing by the wheelchair user.

Thank you again for your proposed decision. As someone who's written about this industry for more than 21 years, I am so happy to think that seat elevation would be covered. I also look forward to CMS's response regarding coverage for standing equipment. Thank you for your time and consideration.

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The American Occupational Therapy Association (AOTA) is the national professional association representing the interests of more than 213,000 occupational therapists, occupational therapy assistants, and students of occupational therapy. The science-driven, evidence-based practice of occupational therapy enables people of all ages to live life to its fullest by promoting health and minimizing the functional effects of illness, injury, and disability. Occupational therapy practitioners help to improve clients’ quality of life and participation in meaningful life occupations. The practice of occupational therapy includes providing mobility assessments and training to Medicare beneficiaries requiring mobility assistive equipment (MAE) including power wheelchairs and power seating elevation. Current Medicare policy covers, as part of the occupational therapy scope of practice, an evaluation of a beneficiary to determine the need for mobility equipment and recommendations by occupational therapists on the type, appropriate fit, and adaptations needed to best meet the patient’s needs. Additionally, occupational therapists provide expertise on proper positioning and training in the use of wheelchairs and other assistive technology. Occupational therapists provide these covered Medicare services under a physician’s order and often as a part of an occupational therapy plan of care. AOTA appreciates the opportunity to comment on the National Coverage Determination (NCD) for Seat Elevation Systems as an Accessory to Power Wheelchairs (Group 3).

Seat Elevation Systems as an Accessory to Power Wheelchairs (Group 3)

As an organization that represents clinicians who treat wheelchair users, we hear from members who are frequently in battles with payers fighting for medically necessary equipment, which are currently considered “accessories.” Many of our members and their clients invest countless hours navigating the complicated appeals process and often give up and pay large amounts of money out of pocket or, regrettably, go without thislife-altering equipment. We are pleased that CMS has proposed to cover one of the critically important systems for power wheelchair users, seat elevation. These systems are critical for daily safety, for instance, when a person with quadriplegia is left alone at home for hours, without a caregiver, because insurance will often not cover enough home health care hours and services to support patient safety needs for wheelchair users. Expanding access to these systems will allow users to accomplish safe transfers from a wheelchair to a toilet, bed, or other surface and allow individuals to live more independently and perform mobility-related activities of daily living (MRADLs). MRADLS are critical to the work of occupational therapy practitioners, who provide skilled interventions to Medicare beneficiaries who are wheelchair users to advance functional status and level of independence. AOTA continues to urge CMS to recognize that functional mobility is an activity of daily living: the need (and coverage) for an MAE should not be linked to the ability to perform activities of daily living (ADLs) or have them performed by a caretaker. Individuals can work, cook, dress, and perform daily hygiene tasks, often without any other assistance, if they are able to use seat elevation systems as an accessory. When an individual experiences a mobility deficit, then that person should meet the basic coverage criteria for a reasonable and necessary item of mobility assistive equipment. The NCD is an encouraging step to ensure that Medicare funds are used effectively and appropriately to ensure that Medicare beneficiaries with specific mobility needs have access to power seating. AOTA applauds the fact that CMS is taking this important step in the right direction.

Power seating functions such as tilt, recline, elevation, and standing allow a person with limited strength and mobility the ability to change position to maintain circulation and soft tissue integrity (Liu et al., 2012). These devices also can interface with complex alternate access systems such as sip-and-puff switch, eye interface, and oral interface technology to enable those with complex mobility limitations to self-propel (Wilson et al., 2012).

We understand you have received numerous peer-reviewed studies proving that these systems can improve circulation, mobility, gastrointestinal health, range of motion, promotion of vital organ capacity, improved bone density, and reduced occurrence of skin ulcers and skeletal deterioration. For example, we cannot underscore enough the devastating, life-threatening, and expensive toll a skin ulcer can have on an individual. Wheelchair users can spend years on bedrest in hopes their skin ulcers heal and often require several surgeries. If an individual survives a wound, Medicare must often cover services and surgeries costing well over $100,000. It seems to us that appropriate coverage of MAE, including seat elevation would be more cost effective and result in built-in savings for CMS.

AOTA continues to encourage CMS to recognize that performance of several IADLs also requires wheeled mobility and power mobility accessories. The IADLs include:

Communication device use
Community mobility
Financial management
Health management/ maintenance1 (wellness, fitness, medication regimen establishment, etc.)
Home establishment and management
Meal preparation and cleanup
Safety procedures and emergency responses2 and
Shopping (grocery and other)
Care of others (including selecting and supervising caregivers)
Child rearing
Care of pets

The above-mentioned IADLs are critical aspects of mobility. AOTA strongly urges CMS to consider AOTA’s IADL definitions as part of its NCD.These activities represent highly complex teaching and training processes that require skilled therapeutic intervention and have long been foundational components of occupational therapy practice.

Individuals dependent on wheeled mobility also may be hindered in their ability to engage in the occupation of work, regardless of whether their place of work is within the home or in the community. The Occupational Therapy Practice Framework: Domain and Process defines ‘work” as:

Employment interests and pursuits
Employment seeking and acquisition
Job performance
Retirement prep and adjustment
Volunteer exploration and
Volunteer participation.

(The American Journal of Occupational Therapy, 2020, Vol. 74(Supplement_2), 7412410010p1–7412410010p87. https://doi.org/10.5014/ajot.2020.74S2001)

Employment is one of the many daily occupations that may require assistive mobility. Facilitating work performance will ultimately decrease Medicare expenditures as individuals may be self-supporting.

Additionally, these MAEs not only improve beneficiaries' ability to perform ADLs and IADLs, adequate seating, positioning, and use of appropriate devices for mobility, they also allow a client to interact within the community and pursue opportunities for participation at the clients’ desired level. Assistive devices can facilitate quality of life (Devitt, Chau, & Jutai, 2004) and psychological and social well-being (Day & Jutai, 1996; Day, Jutai, & Campbell, 2002; Shea et al.). Conversely, a lack of access or devices that do not provide the intended result can negatively affect a person’s overall health and well-being (Gray, Quatrano, & Lieberman, 1998; Hunt et al., 2004; National Council on Disability, 2000; Scherer & Glueckauf, 2005).

Power seat elevation systems are integral to enabling independence within the home environment and mitigating medical comorbidities that often occur with chronic healthcare conditions that impair mobility. Power seat elevation on power wheelchairs is integral for people with chronic mobility limitations. Power seat elevation systems reduce the risk of repetitive strain injuries and pain in a power wheelchair users’ shoulders and neck by raising them up to the level of the object for which they are reaching.
Additionally, they aid transfers by enabling the power wheelchair user to change their seat to be equal height with what they are transferring to. These issues are of critical concern for occupational therapy practitioners treating beneficiaries in power wheelchairs who require power seat elevation to function at their fullest ability to perform ADLs and IADLs and remain safe in their home and community.

AOTA strongly supports this proposed NCD that allows CMS to update its Medicare coverage policies to include power seat elevation which would dramatically increase access to this critical technology for beneficiaries who spend all or most of their time in a Group 3 chair.

We would also encourage CMS to extend their proposal to include reach and line of sight and Group 2 wheelchair users in the coverage determination.

Improving Reach and Line of Sight

Group 3 wheelchair users would greatly benefit from increased reach and improved line of sight provided through seat elevation in the final NCD. We would encourage CMS to conduct a comprehensive evidence search to fully consider other benefits of seat elevation, including reach and line of sight. For the current proposal, CMS limited its own evidence review to only clinical studies regarding transfers. The evidence base, subject matter expert consensus, and patient-centered outcomes data all support the medical benefits for reach and neck positioning/line of sight in the built environment. The benefits of seat elevation include reduction of musculoskeletal disorders in the shoulders, upper spine, and neck by limiting the need to constantly reach over one’s head and look up; reduction of neck pain and discomfort by improving line of sight; improved safety when performing mobility-related activities of daily living (MRADLs). In short, reach and line of sight are critical and necessary to improving wheelchair users’ health, safety within the home, and quality of life and beneficiaries should be able to access seat elevation to address these needs and AOTA encourages CMS to include these functions of seat elevation in the final NCD.

Seat Elevation for Group 2 Power Wheelchair Users

The Group 2 power wheelchair user population typically includes people with certain chronic medical conditions impacting cardiovascular and pulmonary function (e.g., congestive heart failure, osteoarthritis, and COPD), lower extremity Acquired Loss of Limb(s), autoimmune diseases (e.g., Inclusion Body Myositis, Lupus, Myasthenia Gravis, Rheumatoid Arthritis, Scleroderma, etc.), and (Poly)Neuropathies. This differs from the Group 3 power wheelchair user population who have a congenital skeletal deformity, myopathy, or neurological diagnosis. Seat elevation can help Group 2 power wheelchair users safely transfer to/from their power wheelchair and gain access to the vertical environment to perform MRADLs, like toileting, bathing, and grooming. Occupational therapy practitioners evaluate and treat Medicare beneficiaries with all conditions in the Group 2 category and assert that the therapeutic and functional benefits to these populations of access to seat elevation is equally critical and significant. Seat elevation provides a basis for level transfers to reduce upper extremity strain during lateral transfers and lower extremity strain during “sit-to-stand” transfers. If Group 2 users’ mobility is limited to the point where seat elevation would be reasonable and necessary for their medical needs, they should not be excluded simply because their diagnosis does not fit into the specific diagnoses listed under the Group 3 coverage criteria. AOTA urges CMS to include Group 2 power wheelchair users in the final NCD.

Clarity on proposed limitations of “weight-bearing transfers”

AOTA would also like to request that CMS provide additional clarity in the final NCD. Specifically, we are asking for additional detail and clarification on the following items:

“Weight-Bearing Transfers” - clarification on CMS’ proposed definition of “weight-bearing transfers” and beneficiaries that might be excluded from coverage based on this definition.

Patient Transfer Devices - clarification on whether beneficiaries who use a patient transfer device such as a floor or ceiling-mounted lift to transfer in and out of their wheelchair would qualify for coverage of seat elevation under this proposed NCD.

Evaluation Criteria – aligning the requirements for evaluations for seat elevation, including qualifications and criteria for the practitioner conducting the evaluation, with the current requirements for similar evaluations performed for CRT wheelchair bases and other power seating functions covered by Medicare.

AOTA urges CMS to clarify these questions to ensure that all beneficiaries who would benefit from seat elevation are able to access coverage under the final NCD decision.

AOTA appreciates the opportunity to comment on the proposed National Coverage Determination (NCD) for Seat Elevation Systems as an Accessory to Power Wheelchairs (Group 3). We would be happy to discuss our above requests in greater detail. If you have questions or need additional information, please contact me at (240) 752-1178 or via email at jlenhardt@aota.org.

Sincerely,

Julie Lenhardt
Manager, Reimbursement and Regulatory Policy

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As someone who [PHI Redacted] has relied on a wheelchair for mobility, I am extremely happy to hear that Medicare is considering coverage for seat elevation and standing features on power chairs. I currently use a manual wheelchair, so while I am not able to be approved for a power chair myself, I still recognize how amazing and productive it would be to have these features.

I wish I had the ability to reach places that are above my very limited reach while seated in my wheelchair. People don't realize how many things are completely out of reach for someone who is confined to a seated position throughout their entire lives. I cannot access any of the cabinets that are above the counters in my kitchen, laundry room, or bathrooms from my wheelchair. Having the ability to access those places would make a huge difference in my day to day life!

[PHI Redacted] I had the opportunity to use a standing machine. I was actually amazed at how much of an impact the simple ability to stand could have for someone that's paralyzed. Just using it for an hour each day over two weeks, standing had significantly improved my bowel function and spasticity. Standing had also helped with my breathing and blood pressure regulation as well. Considering that I had those benefits after only being paralyzed for a month, I cannot even begin to imagine how greatly I could benefit from standing now, 14 years after the fact!

I applaud your decision to reconsider approving these functionalities for power chair users! Doing so will provide so many benefits for everyone who is confined to power chairs for their mobility needs. When the day comes where I need to switch over to a power chair myself, having access to those abilities would be immensely impactful and beneficial!

Thank you for your time and willingness to reconsider these decisions!

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I am a pediatric physical therapist who works with kids who have disability diagnoses, and I help provide them with the necessary Complex Rehabilitation Technology (CRT)/Adaptive Equipment that they require to increase their mobility and independence. I have been working in the Pediatric CRT area/Seated and Wheeled Mobility evaluating for, assisting in adjusting, and training for the use of the equipment for 19 years. This has included the provision of powered mobility and powered seat elevation systems.

Many of the children I work with who use powered wheelchairs for mobility, also require the use of power seat elevate to change their vertical position in space to be able to reach items throughout their homes and to allow them to transfer between surfaces that are level or down-hill (for example wheelchair to bed or toilet). In order for them to learn how to access their environments using their power wheelchairs, and gain the highest level of independence possible with transfers, ADLs (activities of daily living), and MRADLs (Mobility Related Activities of daily living), many of them require power seat elevate to accomplish these tasks, especially related to their smaller bodies with shorter upper extremity reach distances and overall shorter stature.

1. Primarily medical in nature
2. Meeting the requirements to be deemed DME (Durable Medical Equipment)
3. Reasonable and necessary for Medicare beneficiaries.

1. To provide access to this enabling technology
2. For Medicare beneficiaries who qualify for this benefit
3. As an essential component of a complex rehab power wheelchair

As a Pediatric Physical Therapist, I do recommend Group 4 and Group 5 Power (pediatric) Power Wheelchairs to patients at times, as those are required to meet their medical needs. I want to encourage CMS to consider extending coverage for power seat elevation systems as an accessory to complex rehab power wheelchairs (Group 3 AND HIGHER—Group 4 and Group 5).

I completely agree that seat elevation systems are a critical component for many Medicare beneficiaries to transfer to/from their power wheelchairs and applaud CMS for recognizing that: 1. Transferring from wheelchair to other surfaces (bed, toilet, etc.) is a necessary part of the daily routine; 2. Transferring is a means to accomplish MRADLs (moving from one surface to another to complete ADLs) and is therefore considered medically necessary; and 3. Seat-elevating devices improve transfer biomechanics, safety, and independence.

I support CMS’ proposed criteria that transfers may be accomplished with or without caregiver assistance and/or the use of assistive equipment, but request CMS confirm the assistive equipment used to complete the transfers is not limited to the examples provided.

I am also concerned that the reference to “weight bearing transfers” may exclude certain beneficiaries from accessing a seat elevation system, especially if they cannot transfer themselves and require the use of a mechanical lift for transfers. I encourage CMS to consider coverage for these individuals, so that they can use their upper extremities to complete reaching tasks from an elevated position to increase their functional reach.

For example, many children I work who have neuromuscular diseases (ie: Duchenne Muscular Dystrophy, Spinal Muscular Atrophy, etc.) have excellent distal (hand) control and can use their hands to complete many tasks. However, they have very weak proximal muscles (trunk and shoulders), which prevent them from lifting their arms higher than their armrests. Using powered seat elevate, they can adjust their vertical position to match the table, counter, desk, sink, or other surface, to be able to then independently use their hands to complete many ADLs, while supporting their arms on their armrests or on the surface at the same height. This allows many of these individuals to be able to eat more independently, prepare food, brush their teeth, wash their hands, etc. They would not be able to complete these vital ADLs without elevating/adjusting their vertical position to that exact position needed using the power seat elevate function.

I encourage CMS to include coverage for Medicare beneficiaries who need a seat elevation system to reach the locations, surfaces and objects in their home required to support their health, safety, and perform or participate in their MRADLs.

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Disability Rights Pennsylvania (DRP) is the organization designated by the Commonwealth under federal law to protect the rights of and advocate for Pennsylvanians with disabilities. DRP works to ensure that individuals with disabilities can live the lives they choose, free from abuse, neglect, discrimination, and segregation. We are pleased to be given the opportunity to comment on CMS’s Proposed Decision Memo regarding whether seat elevation systems on Group 3 power wheelchairs falls within the benefit category for durable medical equipment (DME) under the Social Security Act.

We support CMS’s proposal to add seat elevation systems on Group 3 power wheelchairs to the benefit category for DME when an individual performs weight bearing transfers and has undergone an evaluation assessing their ability to use the equipment safely.

We support this proposal because, as noted in the memo, the average wheelchair user performs transfers 11 to 20 times per day, so it is important that they can complete transfers with ease, as they are a regular part of their day. In addition, it is important that wheelchair users be able to significantly limit their risk of developing overuse injuries or related impairments that may result from repeated transfers.

Seat elevation systems are a form of assistive technology that make transfers easier for wheelchair users and decrease the likelihood that they will develop an overuse injury or other such impairment. Thus, for many wheelchair users, they are essential to maximizing their independence and improving their quality of life.

We do note that the conditions laid out for seat elevation equipment requires consideration of how the individual does things “in the home”. DRP has had clients who live in Assisted Living Facilities and receive minimal supports, who had staff assume that the individual was not eligible for certain durable medical equipment because they were not residing in their own home. CMS should make clear what constitutes a home and ensure that individuals are eligible if they meet the criteria proposed.

We also have concerns about the terminology “uneven transfer” when the evidence presented throughout the proposed rule shows that injuries occur due to repetitive injuries and stress from transfers but not uneven transfers. We request that this language be removed or modified to better reflect the studies of how injuries occur related to transfers.

CMS notes that “the majority of Group 3 Wheelchair users are diagnosed with conditions that include but are not limited to Parkinson’s Disease, Multiple Sclerosis, Cerebral Palsy, Paraplegia (unspecified), Quadriplegia, Post-Polio Syndrome, and Amyotrophic Lateral Sclerosis (ALS).” Thus, they have significant mobility impairments and are more likely to struggle with various types of transfers, including stand-pivot transfers. They are also more prone to falling when transferring than are other wheelchair users.

We are pleased to see that CMS is taking the position “that for individuals with Medicare who qualify for Group 3 power wheelchairs, the primary purpose of power seat elevation equipment is to avoid or reduce shoulder pain and injury associated with transfers. Thus, the power seat elevation equipment used in combination with a Group 3 power wheelchair is primarily and customarily used to serve a medical purpose.” We agree that this is the appropriate finding as it relates to the criteria that DME must be used to serve a medical purpose.

CMS should listen to those most impacted by this potential change: Group 3 Wheelchair users. Group 3 Wheelchair users overwhelmingly voiced their support for adding seat elevation systems to the definition for DME during the initial 30-day public comment period in 2022.

We also support adding power seat elevation equipment on Group 2 power wheelchairs to the DME benefit category because many people who use their wheelchairs for 12 to 18 hours per day are Group 2 power wheelchair users. This could be because an evaluation did not rule out a Group 2 chair as being able to meet their needs, and as a result Medicare would not pay for a Group 3 chair. Or it could be because they do not have a mobility limitation that is due to a neurological condition, a myopathy, or a congenital/skeletal deformity, a prerequisite to Medicare coverage for a Group 3 wheelchair. There are likely many people who would benefit from using a Group 3 power wheelchair but who do not have the financial means to get one when Medicare denies coverage, so they remain a Group 2 user but still have complex mobility needs that make transfers more difficult.

Someone in this position could avoid shoulder pain and the injuries associated with transfers if they were able to utilize a seat elevator. CMS should find that power seat elevation equipment on Group 2 power wheelchairs primarily and customarily serves a medical purpose.

We thank you for consideration of our comments. Please contact Jennifer Garman, Director of Government Affairs with questions.

Sincerely,

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SUBMITTED ELECTRONICALLY VIA Medicare Coverage Database Portal?

The Honorable Chiquita Brooks-LaSure? Administrator? Centers for Medicare and Medicaid Services? 7500 Security Boulevard? Baltimore, MD 21244? Re: CAG-00461N: Seat Elevation Systems as an Accessory to Power Wheelchairs?

Dear Administrator Brooks-LaSure:?

Thank you for the opportunity to comment on this proposed National Coverage Determination (NCD) that would expand coverage for power seat elevation equipment on certain power wheelchairs to Medicare members.

Please accept the following comments from the Amputee Coalition. The Amputee Coalition was founded in 1986 to advocate and support people who experience limb loss and limb difference. The Amputee Coalition works to ensure all people are supported pre-/post-amputation and during recovery. Our Coalition also works to ensure that individuals have education and access to critical resources. We submit these comments seeking to improve the quality of life among the estimated 2.1 million individuals that have experienced limb loss/difference.

The Amputee Coalition is supportive of Centers for Medicare & Medicaid Services’ (CMS) proposal to expand coverage for power seat elevation equipment on group 3 power wheelchairs through Medicare and we support extending that determination to include Group 2 power wheelchairs.

In support of this position, we point to feedback and research shared by:

The American Medical Association (AMA) May 2020 letter to CMS: “[S]eat elevation facilitates improved transfer biomechanics, enhanced visual orientation and line-of-sight, supports physiological health, safety and well-being, decreases hyperlordotic neck positioning, and reduces the risk of falls and shoulder injuries that are commonly associated with long-term wheelchair use. Additionally, [these] accessories enable individuals with a mobility deficit, sufficient to impair their participation in mobility-related activities of daily living, to do things such as toileting, feeding, dressing, grooming, and bathing in customary locations in the home.¹ As such, these accessories are primarily medical in nature and essential for the health of wheelchair users.” ²

ITEM Coalition March 2023 Letter to CMS: “Beneficiaries with limb loss who use Group 2 power wheelchairs may or may not be able to wear prosthetic limbs. In situations where a beneficiary is not able to perform a stand-and-pivot transfer due to limb loss, seat elevation becomes all the more important to their ability to perform mobility related activities of daily living (MRADLs). These beneficiaries are at the same risk as Group 3 users for shoulder, neck and back pain and injury due to the need to reach to perform many MRADLs in the home.”???

Rehabilitation Engineering and Assistive Technology Society of North America: “The negative psychosocial impact from the lack of vertical mobility, including the inability to communicate and interact face-to-face in social environments and with family and friends, may lead to loneliness, depression, anxiety, substance or alcohol abuse, and isolation.” ³

The Amputee Coalition is pleased to elaborate on these comments and appreciate the opportunity to share them.

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I have been involved in the provision of power wheelchairs and related seating/positioning systems as a supplier and advocate for over 35 years. During this time, I have interacted with thousands of people with disabilities across the country who use power wheelchairs. I thank CMS for their review of the Medicare coverage of power seat elevation equipment and offer the following comments and recommendations:

1- While I support the proposed decision to extend Medicare coverage to power seat elevation equipment, I do strongly recommend this coverage be extended to all qualified power wheelchair users, not just those who use a Group 3 power wheelchair. This would include Group 2 power wheelchairs along with Group 4 and 5 power wheelchairs. Power seat elevation equipment used with these wheelchairs meets the definition of Durable Medical Equipment. Any person who requires a power wheelchair and also meets the “qualifying conditions” for power seat elevation equipment should have access regardless of the power wheelchair base category.

2- I strongly recommend CMS expand the “qualifying conditions” beyond what is proposed. It is not appropriate to narrowly define the coverage policy. Qualifying conditions should include coverage of power seat elevation equipment when it is required for a person to complete their medically necessary Mobility Related Activities of Daily Living (MRADLs). This would align with Medicare’s coverage policy for power wheelchairs.

3- By reference I incorporate the submitted comments from the ITEM Coalition, the United Spinal Association, the Clinician Task Force, and the National Coalition for Assistive and Rehab Technology. These comments provide additional detail and supporting information.

4- I believe CMS will be receiving many comments from individual medical professionals and related associations. Comments will also be received from many people with disabilities and their local and national disability organizations. These comments are evidence of the widespread national need and support for the coverage of this important technology.

On a related note, I encourage CMS to open for public comment the NCD Reconsideration Request for coverage of power standing equipment used with power wheelchairs. This request was also submitted in September 2020 for technology that also brings significant medical benefits to people who require power wheelchairs. Medicare coverage is long overdue, and CMS should move expeditiously to open the public comment period on this NCD Reconsideration Request that was submitted over 30 months ago.

Thank you for your consideration of these comments and incorporating them into the final decision memorandum and related policies. This will allow proper access to this well-established and needed technology and address the medical and functional needs of people with disabilities who use power wheelchairs.

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We, National ADAPT, fully support Medicare's proposal covering seat elevation systems on power wheelchairs for people with disabilities. Seat elevation gives people with disabilities the ability to be more independent and productive lives.

We hope this opportunity will also get proposed for disabled wheelchair user who received Medicaid as well. All people with disabilities regardless of which medical assistance they receive, should be eligible for the same opportunities.

In Solidarity,

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As a longtime supporter of Rehabilitative Technologies, I am writing to express my strong support for the inclusion of seat elevation systems as an accessory to Group 3 power wheelchairs under the Medicare program. In particular, I would like to highlight the benefits of seat elevation systems in relation to transferring patients.

Transferring patients in and out of wheelchairs is a task that is often challenging and physically demanding, both for the caregiver and the patient. The use of seat elevation systems can greatly facilitate this process by raising the height of the seat and bringing the patient to a more convenient and accessible height for transfers. This can reduce the risk of injury to both the patient and the caregiver by minimizing the need for awkward bending or lifting postures.

Moreover, seat elevation systems can provide additional benefits in the context of transfers. For instance, when a patient is at a higher level, it may be easier to align their center of gravity with that of the caregiver, facilitating smoother and more stable transfers. Additionally, being at a higher level can give patients greater visibility and control over the transfer process, increasing their sense of independence and reducing anxiety.

Despite the significant benefits of seat elevation systems for transferring patients, they are not currently covered by Medicare as an accessory to Group 3 power wheelchairs. This exclusion means that many patients are unable to access these essential systems due to the high cost of purchasing them out-of-pocket.

I urge the Centers for Medicare and Medicaid Services to consider including seat elevation systems as an accessory to Group 3 power wheelchairs under the Medicare program. By doing so, many patients will be able to access these vital systems, enabling them to enjoy improved safety, independence, and quality of life.

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To Whom It May Concern,

As a 30 year veteran of the Complex Rehab Industry I am in full support of CMS funding power seat elevation technology on powered mobility wheelchairs. This is a beneficial feature for both individuals using a Group 2 or Group 3 power base and seating. The power seat elevation technology enables certain individuals to perform mobility related activities of daily living independently. The following list of medically necessary functions that the power seat elevation allow the end user to accomplish independently.

* Facilitate reach biomechanics, safety and range
* Improve transfer biomechanics, safety and independence
* Enhance visual orientation and line-of-sight
* Support physiological health, safety and well-being.
* Decrease hyperlordotic position of the neck
* Promote stable seated positioning
* Reduce symmetric tonic neck reflex (STNR) activity
* Improve safety with performance/participation in ADLs.
* Promote communication, social engagement, self-esteem and integration.
* Improve wheelchair pedestrian safety.

In addition to the the items listed above power seat elevation helps facilitate independent transfers which will allow individuals to continue to live independently for longer and contribute good mental health.

I am urging the CMS to consider including power seat elevation systems as an accessory to Group 2 and Group 3 power wheelchairs under the Medicare program. This accessory will greatly improve the quality of life for individuals that rely on power mobility to be independent inside of the home.

Thank you for your time and consideration in this matter.

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I strongly support this proposed decision by the Centers for Medicare and Medicaid Services (CMS) to offer coverage for seat elevation systems used in power wheelchairs. Medicare is absolutely making the right decision, and they can go further to ensure that everyone who needs access can get it.

[PHI Redacted] while my chair has allowed me to be mobile and has allowed me to go to physical therapy and doctor appointments along with the ability to participate in social activities (e.g., movies, shopping, going out to dinner), I feel that the addition of power elevation and power standing features to my chair would greatly enhance my life and increase my independence. When I was first being fitted for my wheelchair, I was told that an elevation and/or standing feature was seen as “not medically necessary” and that we (my wife and I) would have to absorb the costs. This is a cost that we cannot afford. I firmly believe that these features are medically necessary and the costs should be covered by insurance.

By having power seat elevation and power standing features approved for installation in my wheelchair:

I know some of these tasks sound simple and mundane. But realize this: I was completely independent before my injury and could perform tasks like the ones I listed above along with many more. My wife and I were also able to travel and I was looking forward to continuing my career. We were supposed to relocate to be near her family. If I was able to have these features in my chair, it would open up my independence, and we could once again travel. I might also be able to drive again.

Standing features have been shown to have numerous medical benefits including improved circulation, promotion of bone density, improved GI tract function, improved mobility and lower limb function, reduced risk of contractures, and reduced occurrence of pressure ulcers and skeletal deformities. Likewise, seat elevation facilitates improved transfer biomechanics, enhanced visual orientation and line-of-sight, supports physiological health, safety and well-being, decreases hyperlordotic neck positioning, and reduces the risk of falls and shoulder injuries that are commonly associated with long-term wheelchair use.

Based on my medical condition, I qualify for a Group 3 power wheelchair. The primary purpose of power seat elevation equipment is to avoid or reduce shoulder pain and injury associated with transfers. I personally have a torn right rotator cuff, and transfers at times can be very painful. I am trying to avoid surgery because I am working hard to get stronger and thus more independent. The power seat elevation equipment used in combination with a Group 3 power wheelchair is primarily and customarily used to serve a medical purpose.

Standing features and seat elevation will improve my overall health and will allow me to perform mobility-related activities of daily living. This makes these devices “medically necessary.” Seat elevation and standing features improve the overall health of mobility impaired beneficiaries and enable individuals to perform mobility-related activities associated with daily living that they otherwise would be unable to do.

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I wish the people who make the decisions for my life would just take a moment to think of the impact they have on the lives of millions of Americans. What if all of our elected officials spent a day in a wheelchair from when they get out of bed in the morning, through their activities of daily living (ADLs), COMMUTE, work, USING A PUBLIC BATHROOM and be sure to try and go basic grocery shopping all from that chair they transferred into that morning when they started their day.

Think outside the box people. One size does not fit all. Actually, my family has a saying "One size fits none."

My son cannot have a wheelchair because he can walk with braces. But what about when his braces are broken? What about when he takes his shoes and braces off at home for the evening so the wound he has on the bottom of his foot can "air out." He is robbed of all dignity and crawls on his hands and knees hoping he doesn't rub new wounds on the tops of his feet. [PHI Redacted], walks with aides and therefore could never possibly need a basic wheelchair to get from point A to point B.

What about people who aren't average any longer because life robbed them of their averageness and they no long can comfortably sit in a wheelchair built for average people? Average=normal. Disabled=second class. I have no doubts about it.

I would simply ask that as you make decisions about the lives of the not-so-abled you would kindly not cause further challenges or harm. Make your decisions based on what our lives need, not what makes you popular.

PS I also think our elected officials should have the same crappy managed Medicaid we have to deal with. Same rules.

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To Whom It May Concern,

I fully support CMS funding power seat elevation technology on powered mobility wheelchairs, for both Group 2 and Group 3 power bases, as this technology enables certain individuals to perform the following medically-necessary functions:

* Facilitate reach biomechanics, safety and range
* Improve transfer biomechanics, safety and independence
* Enhance visual orientation and line-of-sight
* Support physiological health, safety and well-being.
* Decrease hyperlordotic position of the neck
* Promote stable seated positioning
* Reduce symmetric tonic neck reflex (STNR) activity
* Improve safety with performance/participation in ADLs.
* Promote communication, social engagement, self-esteem and integration.
* Improve wheelchair pedestrian safety.

For these reasons, I encourage CMS to approve funding for power seat elevation technology for those beneficiaries who qualify.

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My name is Jacky, [PHI Redacted], and current wheelchair user. I also volunteer with team river runner, and work with many paralyzed individuals on a seasonal basis. I support seat elevations and standing systems because they allow freedom from being ‘stuck’ sitting. They allow users to meet ADLs more independently- such as cooking with out fear of hot grease in your face, or reaching an item on a grocery shelf with out needing to ask someone else to reach it for you! I have seen with my own experiences working with mobility challenged individuals how being able to stand can relieve chronic pain caused by sitting in one position ALL day, and that it aids in circulation changes to the legs and hip complex, increasing the health of the body with assisted movement. Being able to stand freely with assistance at the push of a button allows users to prevent contracture of their hips and knees, by standing erect as many times a day, anywhere they are, as needed. It improves the quality of their lives tremendously. It improves their moral, and emotional health. It gives them the ability to speak and interact with others, at their full height! Something you don’t think about until you are in a wheel chair, with a crick in your neck from constantly looking up at everyone who is standing around you. Trust me, everyone feels like giants when you are in a wheelchair.

Medicare has met my prosthetic needs, and I am extremely grateful for this. As a manual chair user, with hopes of walking again, I myself, do not need a power chair. But I urge you (Medicare and Medicaid) to finalize your proposal to cover seat elevation systems and power standing chairs for beneficiaries. The dividends of this provision cover physical needs, emotional needs, and psychological needs, all contributing to overall health in a beneficiary, leading to reduced health costs for Medicare and Medicaid. It gives the beneficiary more independence, greater self esteem, and more ability than they have from a fixed sitting position.

Next time you need to make a meal, cook some bacon, boil a small pot of water, try it from a chair sitting next to your stove. Tell me you don’t fear getting burned. Even greater than that, is the risk when one goes to remove a pot or pan from the stove to pour hot water or put food into a plate. That takes a great toll on shoulder sockets and wrists. (Accident happen, which lead to further issues. I.e. a paralyzed individual with lessened healing ability of their legs gets burned, creating long term need of wound care). If this person could have stood to cook, even if they’re dropped their hot item, it would not land on their lap. Standing power chairs also allow for greater access to things like cabinets. It allows a user to make use of their living space much better, especially if their living space is not custom built for wheelchair height optimization. Most people can’t afford that but an elevated seat or standing chair affords them the ability to reach beyond sitting height of a manual chair.

Medicare, by meeting my prosthetic needs, you have enabled me to enter back out into the world and work. You have also enabled me to enrich others lives with adaptive recreation, adding my own support to mental and physical health of all the people I work with.

Thank you for the care you provide, I never would have been able to afford my prosthetics out of pocket and it means the world to me to have to mobility I do with your help. Thank you for making a difference in peoples lives.

Thank you for the opportunity share my views on your proposal to cover seat elevation and standing systems. I urge you to pass this coverage. The numerous benefits beyond what I have mentioned in patient health can decrease other costs to your system.

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I have many patients who are in power wheelchairs. I know that the elevation feature is extremely beneficial since different situations call for different heights. One situation that comes up often at work is when wheelchair-bound patients need to have eye exams. If the patient cannot get out of their wheelchair and into the treatment chair, they must be able to raise and lower their height to meet the equipment in the ophthalmologist's/optometrist's office. The same concept is applicable to dental care.

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Using the seat elevation for a power wheelchair.
[PHI Redacted] I use my power wheelchair in my everyday activities. My wheelchair has the elevation feature and that particular function has improved my independence for living life with more dignity and affording me a better quality of life. I can live a healthy and safe lifestyle without relying on my caregivers as much. It allows me to work in the kitchen to prepare meals, reach the microwave above the stove, reach the cupboards for food and dishes, and reach the tall shelves in my refrigerator. In the bathroom, I am able to raise it to sink level for toiletry, looking in the mirror for brushing teeth and styling my hair. In the bedroom, the chair can be raised to meet the height of the mattress for level and safer transfer from chair to bed and vice versa. There is a reduction in the risk of falls that could result in fractures and shearing from pressure sores which is incredibly important. When cleaning the house, particularly dusting of furniture, the elevation function raises me to the level of tall cabinets or the top of the refrigerator.

Having the seat elevation function has changed my life [PHI Redacted] and has allowed me to have more independence from my caregivers. I implore Medicare to approve this function as being medically necessary, so those with physical disabilities can continue to be as independent as possible.

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On behalf of Smith & Nephew, Inc. (Smith+Nephew), I am pleased to support the proposed National Coverage Determination (NCD) for power seat elevation systems in power wheelchairs. We applaud the Centers for Medicare and Medicaid Services’ (CMS) recognition that these systems in Group 3 power wheelchairs fall within the Durable Medical Equipment (DME) category.

Smith+Nephew is a portfolio medical technology company that exists to restore people’s bodies and their self-belief by using technology to take the limits off living. We call this purpose “Life Unlimited.” Our 18,000 employees deliver this mission every day, making a difference in patients’ lives through the excellence of our product portfolio, and the invention and application of new technologies across our three global franchises of Orthopaedics, Sports Medicine & ENT, and Advanced Wound Management.

As a wound care company, Smith+Nephew is all too familiar with the pressure injury prevention challenges faced by Medicare patients who have limited mobility and rely on wheelchairs. For these patients, the importance of weight shift and pressure relief maneuvers – including power seat elevation systems – cannot be overstated. That is because, if a pressure injury develops, the treatment burden for the patient and caregivers is high, time to healing can be long, and the health care costs are significant.

Thank you for the opportunity to provide comments on the NCD. Please do not hesitate to contact me if you have any questions.

Sincerely,

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I am writing in support of the National Coverage Determination (NCD) to allow for coverage of power seat elevation on complex rehab power wheelchairs within the Medicare Durable Medical Equipment (DME) benefit.

After I retired from an eight year career in the NFL, I was diagnosed with [PHI Redacted]. When I was diagnosed, I was told I only had 2-5 years to live. I was expected to fade away quietly and die.

For me, that was not ok. I did some research and found that with the right equipment and the right technology, I could live and be productive in our society for decades. I have no intention of fading away quietly. That was a decade ago.

As an organization, it is our mission at Team Gleason to encourage and foster advances in technology for those with the most need. The technology I use is not a luxury, but an essential extension of my person. Limiting people's access to this technology in any way, would not only be limiting their potential, but also inhibiting their will to live.

In January of 2020, Congress honored me with the Congressional Gold Medal in recognition of my and our work for people with ALS and their families to live productively and purposefully. It is in that role that I write to you today.

I am very fortunate that I am able to afford, and have access to, the technology and tools I use to live and be productive. As an individual living with [PHI Redacted], power seat elevation has allowed for greater participation in daily life. The technology aids with transfers from the power wheelchair to the bed, commode, or other surface and allows for great participation in mobility related activities of daily living, the standard for Medicare coverage under the DME program.

Without the daily use of this technology, I would not only be limited in activities, but my caregiver would be extraordinary burdened and one or both of us could be injured.

I'm encouraged that CMS is considering the necessary changes that acknowledge the medical necessity of seat elevation. I strongly urge CMS to consider power seat elevation as medically necessary for in-home use for not only transfers, but also reach, accessibility, and increased independence and therefore covered under the DME benefit. This technology is not only an integral part of my power wheelchair but an integral part of my life.

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I am writing to express my support for your proposal to provide coverage of power seat elevation for people with mobility impairments. I want to thank you for giving users, providers, clinicians, and all supporters of the complex rehabilitation community a chance to share their stories and provide feedback on this important issue. It is critical that policymakers have the opportunity to hear directly about the current challenges in making power seat elevation accessible to all who would benefit from it.

As you move forward with developing coverage criteria for power seat elevation, I urge you to consider expansive coverage criteria that aligns with current, industry-recognized research that has shown, when paired with the appropriate mobility base, that seat elevation can not only improve the performance of mobility-related activities such as transfers but also support physical and mental health goals, promote increased independence with activities of daily living (ADLs), and improve environmental accessibility.

Given all the significant benefits of power seat elevation for individuals with mobility impairments, I urge you to consider swift, meaningful, and comprehensive action to ensure that equitable access to this technology is made available as soon as possible to all individuals for whom it would mean improved independence, safety, and quality of life.

Thank you again for your efforts in providing a platform to discuss this critical issue.

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CMS Request for Public Comment re: Seat Elevation, Round 2

Regarding CMS’s proposal that power seat elevation on Groups 2 and 3 power wheelchairs, which are also capable of seat elevation: The Group 2 chair is a reasonable, more affordable option for beneficiaries who are medically appropriate for a Group 2, but not a Group 3, and particularly for beneficiaries without secondary insurance coverage. In addition to savvy resource utilization for consumer and payer, the clinical benefit of seat elevation should be accessible to all end users who meet medical necessity for Group 2 or Group 3 chairs.

Proposed additional reasons to consider seat elevation funding, and expand coverage conditions:

Cost preserved to the person with a disability: Home care daily rates are approximately $200-350/day. Improving independent access to an individual’s environment reduces the need to hire able bodied individuals to supplement their needs. A common use for seat elevation is for independent access to refrigerators (food, medication), microwaves, stove tops. The provision of this power function also reduces safety risks and injuries associated with poor environmental access.

Transfers: Consider diagnoses such as Spinal Muscle Atrophy, Multiple Sclerosis, Muscular Dystrophy as well as individuals with Spinal Cord Injuries, or Cerebral Palsy. Whether progressive or non-progressive, the disease course of each is highly dynamic in severity and physical presentation. People with these disabilities (not an exhaustive list) often can not sustain their body weight during a transfer using their arms and/or legs but would still reap clinical and functional benefits of having optimal access to their environment (tables, desks, doctors, dentists).

Seat elevators benefit end users who rely on their caregiver to transfer them with a patient lift. Patient lifts should be added to the proposed list of assistive equipment that meet funding conditions. When the space between the transferring person and the distance of travel to the transfer surface is minimized, the risk of injury to the client and caregiver are reduced. Using this seat elevation function to improves transfer safety when using a patient lift with sling provides additional control and safety measures that positively impact skin integrity, safety, ergonomics, as well as protects from damage to the wheelchair or wheelchair components.

Vital Organ Capacity: Existing clinical studies support that a higher operational height for a PWC user promotes postural alignment of the head, neck, and thoracic cavity. Postural alignment affects vital organ capacity, including but not limited to cardiovascular health, respiration, swallowing, digestion/nutrition, bowel, and bladder function.

Visual Perception and safety: Performing activities of daily living with optimal alignment of the head and neck provides access to able-bodied line-of-sight and environmental access to the environment, family, colleagues. The cervical hyperextension of the wheelchair user and the cervical flexion required of their communication partner are neutralized when eye-level conversations are possible. An elevated vantage point also compensates for cervical limitations and oculomotor deficits.

We will all age into or with a disability It behooves the gander to advocate and support policies that improve quality of life, and continually speak up for how the system can be better. Having access to proper health care, including medical device technologies, like complex rehabilitation technology and other assistive devices, impacts each domain within the Social Determinants of Health (SDOH): Economic Stability, Education Access and Quality, Health Care Access and Quality, Neighborhood and Built Environment, and the Social and Community Context.

This is exciting forward movement but begets caution. Policy change is only effective to the extent it is honored and implemented for all Medicare recipients, including Medicare Advantage plan beneficiaries. It’s been observed across healthcare industries that Medicare Advantage beneficiaries do not receive the same access to complex rehabilitation items, or more broadly, medical device technologies. The Medicare Advantage or “Part C” plans boast the added benefits of vision, hearing and dental, but existing policies and practices regarding DME and CRT fail to support the evident need their beneficiaries have in getting safely to, through, and from these appointments. The practices of the privatized Medicare Advantage policies do not appear to uphold the agreement that “plans must cover all medically necessary services and supplies that Original Medicare covers.”

Respectfully, CMS is being encouraged to consider that a “win” for some does not wholly address disparity in public health care for all.

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The Disability Policy Consortium (DPC) strongly supports CMS’s proposal to cover power seat elevation systems for Group 3 wheelchairs in its National Coverage Determination (NCD). DPC is a statewide disability rights nonprofit in Massachusetts, conducting statewide advocacy, policy, research, and healthcare support. We appreciate CMS taking this step to allow some Medicare beneficiaries to live more safely and independently in their homes.

Seat elevation systems are crucial to the health and independence of many power wheelchair users we work with. Not only do these systems allow consumers to perform safe transfers in the home, but they also maintain their health and safety in a variety of other activities and circumstances.

We strongly encourage CMS to expand the basis for coverage to include mobility related activities of daily living (MRADLs), beyond just transfers in the home. The ability to reach higher shelves and surfaces is not a matter of comfort or convenience, but one of health and safety. Without an elevation system, wheelchair users risk burning themselves on the stove or spilling hot food on their lap while attempting to cook. Improving a consumer’s reach helps reduce fatigue, injury, and pain, and prevents adverse medical complications. The ability to be at eye-level with others not only allows for normal conversation without unnecessary, constant strain on the neck, but it also allows the wheelchair user to be seen by others when out in the community, preventing them from being hit by cars on the road or tripped over by pedestrians.

The ability to perform MRADLs saves Medicare money, as it significantly lowers the risk of injury and adverse health outcomes, reduces the need for personal care attendant (PCA) services, and keeps people out of nursing homes.

For all the above reasons, we also encourage CMS to cover standing accessories on wheelchairs. Standing provides pressure relief, which prevents a range of injuries, enhances blood circulation, and promotes a healthy bone density amongst other clear medical benefits.

To conclude, we believe power seat elevation systems for Group 3 and Group 2 power wheelchairs fall within the benefit category for durable medical equipment, and thus support CMS’s proposal to include such systems in their NCD. We further encourage CMS to consider MRADLs and other benefits as a basis for qualifying for these systems, and to consider including standing accessories in the NCD as well. Thank you.

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Hello! I am an Occupational Therapy student, and want to emphasize my support for the coverage of the seat elevation feature on power wheelchairs. I am grateful for the opportunity to advocate for such an important topic. Occupational Therapy is a client centered practice in which we strive to promote participation and independence in a variety of occupations to maximize quality of life and maintain dignity for a variety of human populations. Many of life’s occupations involve standing and to limit coverage for the elevation feature on power wheelchairs would be an extreme disservice to individuals with limited mobility. Examples of occupations that involve standing that power wheelchair users would not be able to do independently include looking into most public bathroom mirrors, reaching higher shelves at the grocery store, cooking at most stoves, interacting with others that may be standing or at a bar, and countless others. Furthermore, data from a study done to examine various power wheelchair features illustrates that when this feature is accessible, it is often utilized for multiple hours per day and users report increased participation and satisfaction in desired occupations (Leister, 2006). Thank you to Medicare for the opportunity to express my support for such an important topic, and I look forward to a brighter future for power wheelchair users.

Elizabeth Klees, OTS

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Hi,
I am a physical therapy by background and currently working for Quantum Rehab as a product specialist. I have worked in these roles for a combined 6 years. During this time, I have recommended many seat elevators to an array of patients. I have written letters of medical necessity. I have had many clients who were unable to transfer out of their chair independently because of lack of seat elevator which caused incontinence in their chair or UTIs, increased shoulder pain from constant overhead motion, and lack of social engagement. I have had patients who are fortunate enough to afford a seat elevator privately fund this for themselves because they saw it as THAT important. My state does support seat elevator through MN Medicaid.

I want to thank CMS for recognizing seat elevators importance and urge you to continue to see the importance of this support. I completely agree with this decision at it will help end users with transfers, access, reduction in pain, and communication with the peers.

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The proposed change will improve patient outcomes and reduce injuries related to transfers in and out of the wheelchair. Based on the literature this item is medical in nature and would align with a medically necessary position:

In order to perform non-level transfers, users must use a variety of techniques such as the side pivot transfer. The side pivot transfer requires the user to push off with their arms and pivot the body about the feet, swinging the trunk onto the target surface. This requires significant use of the upper extremities making the integrity of the arms and shoulders paramount to a successful transfer.

While it likely appears that the proposed position speaks to both power seating elevation and power standing feature. The position could be clearer to state that power standing features are also covered under this proposed expansion for mobility devices.

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Occupational Therapy Student
Dear Center for Medicare and Medicaid Services,
My name is Kauly Almonte, and I am an occupational therapy student pursuing my doctorate degree at Saint Joseph’s University. I was very pleased to hear that for the first time ever you, CMS, have proposed a decision to possibly offer Medicare coverage for seat elevation systems in power wheelchairs. This topic is very important to me as an occupational therapy student seeing as the main goal of occupational therapy is to be client-centered. By offering coverage for seat elevation systems in power wheelchairs you will be allowing the proper engagement in many occupations that are so important for all individuals. I believe that all individuals deserve equal opportunities to be able to do the things they love, and providing this coverage will do just that.
Under the Occupational Therapy Framework 4, an individual’s ability to stand affects all nine occupations listed, however, I will only be addressing two of them in this letter. To start off, under the health management occupation, being able to stand specifically affects the social and emotional health promotion and maintenance, and symptom and condition management of a person. Standing would improve an individual’s social engagement to help support their mental health and wellness. Standing would also improve symptom and condition management in this population. Research suggests that power wheelchair standing devices, also known as seat elevation systems, can reduce the likelihood of contractures worsening and improve both mental and physical health (Bayley et.al, 2020). Not only am I as an occupational therapy student seeing the need for this to be covered by insurance, but there is research that backs the importance of seat elevation systems for individuals who use power wheelchairs.
Next, seat elevation systems would help improve the occupation of social participation. Being able to stand while speaking to someone at eye level is very different than speaking to someone while you are sitting, and the other individual is standing. Imagine having to use a power wheelchair to ambulate and function in your everyday life, but never being able to speak to your family, friends, and others at eye level. Having to literally always be spoken down because you cannot afford a seat elevation system for your power wheelchair. Some may see this as a privileged accessory, but in reality, it is a basic necessity for a person in a power wheelchair to feel as though they are equal to the people who surround them.
As an occupational therapy student, I believe that all individuals deserve the right to participate in all their occupations regardless of their ability. I strongly encourage CMS to approve seat elevation power wheelchair systems to be covered by insurance. By approving coverage, you, CMS, would be helping improve the ability to function in all occupations and the overall lives of individuals who need power wheelchairs to live in this world. Thank you for the opportunity to give my viewpoint as to why coverage for seat elevation systems should be covered by insurance.
Sincerely,
Kauly Almonte OTS

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The American Academy of Physical Medicine and Rehabilitation (AAPM&R) is pleased to submit these comments on the Centers for Medicare and Medicaid Services’ (CMS) proposed National Coverage Decision (NCD) for seat elevation systems in Complex Rehabilitation Technology (CRT) power wheelchairs. AAPM&R has long advocated for coverage of these systems for Medicare beneficiaries and applauds CMS for this proposal.

AAPM&R is the national medical specialty organization representing more than 9,000 physicians who are specialists in physical medicine and rehabilitation (PM&R). PM&R physicians, also known as physiatrists, treat a wide variety of medical conditions affecting the brain, spinal cord, nerves, bones, joints, ligaments, muscles, and tendons. PM&R physicians evaluate and treat injuries, illnesses, and disabilities, and are experts in designing comprehensive, patient-centered treatment plans. Physiatrists utilize cutting-edge as well as time-tested treatments to maximize function and quality of life, and often treat patients with mobility impairments, resulting from conditions such as spinal cord injury, amyotrophic lateral sclerosis, stroke, multiple sclerosis, and many other disorders, that would greatly benefit from access to seat elevation features.

As such, AAPM&R strongly supports CMS’s decision to consider seat elevation as primarily medical in nature and, therefore, a covered durable medical equipment benefit under the Medicare program. AAPM&R also strongly supports that this proposal deems that seat elevation is reasonable and necessary for Medicare beneficiaries with mobility impairments who need seat elevation to perform weight-bearing transfers and aid in the performance of mobility related activities of daily living (MRADLs), with or without assistance from another person.

If finalized, this proposal will advance health equity in the Medicare population and would be a major step forward for the disability population. This proposal would dramatically improve the quality of life for Medicare beneficiaries who utilize power wheelchairs and require seat elevation systems. Allowing beneficiaries with a permanent disability to access technology to stand, reach, and function in their home and community, is not a luxury, nor is it an item of convenience, but a necessity.

While AAPM&R strongly supports this proposed rule, AAPM&R believes that CMS should expand its proposal, as noted below, to ensure that all Medicare beneficiaries who need access to power seat elevation systems will receive coverage for them. The current proposal is a positive first step, but it will leave behind many Medicare beneficiaries who would benefit from access to power seat elevation systems.

Additionally, many other payers currently cover seat elevation systems, demonstrating recognition for the medical necessity of these devices. This raises health care inequities – those who can pay thousands of dollars out of pocket or wo do not rely on Medicare are able to access these systems. Those who cannot pay out of pocket all too often do not have access to these necessary technologies. Many CMS beneficiaries are on fixed or limited incomes, and therefore cannot afford to pay for power seating.

Background

Seat elevation is a vital accessory to power wheelchairs that assists an individual with mobility impairment to raise and lower themselves in the seated position through the use of an electromechanical lift system. Seat elevation allows beneficiaries the ability to adjust their seat to the necessary height to perform or participate in basic, but critical mobility related activities of daily life (MRADLs), such as grooming, cooking, turning on light switches, and accessing medications stored in a medicine cabinet. It is also critical in assisting individuals with transfers from a wheelchair to a commode, bed, or other necessary surface. Use of this system decreases the risk of shoulder, back, and neck injuries, falls, and other secondary injuries related to long-term wheelchair use (e.g., overuse of transfer and reach activities). The seat elevation system also allows for beneficiaries to have less dependence on a caregiver. This results in quality of life and financial improvements, as caregivers and attendants are not covered by most insurances, including CMS.

Qualifying for a power mobility device means a patient must need assistance with activities such as bathing, dressing, grooming, meal preparation and ambulation within the home environment. With power seat elevation, patients can achieve independence, promote safety, reduce medical co-morbidities as well providing privacy and integrity for the most basic human tasks.

Consistent with the extensive support of physiatrists for expanding access to and coverage of assistive devices for their patients who would benefit from this care, physician delegates from AAPM&R successfully introduced and passed a resolution in the American Medical Association’s House of Delegates 2019 Interim Meeting regarding the support of the physician community for expanding access to seat elevation systems for power wheelchair users. This resolution reads:

“RESOLVED that our American Medical Association request that the Centers for Medicare and Medicaid Services (CMS) render a benefit category determination (BCD) that establishes that the seat elevation and standing features of power wheelchairs are primarily medical in nature and qualify under the definition of durable medical equipment (DME) when used in a power wheelchair.”

Reach and Line of Sight

AAPM&R urges CMS to expand their coverage to include Group 3 wheelchair users who would benefit from increased reach and improved line of sight provided through seat elevation.

The evidence base supports the medical benefits for reach and neck positioning/line of sight in the built environment. Seat elevation reduces neck pain and discomfort by improving line of sight for power wheelchair users, and supports reduction of musculoskeletal disorders in shoulder/upper extremities by limiting the need to constantly reach over one’s head. Improved reach and line of sight through seat elevation also makes performance of MRADLs easier for wheelchair users.

AAPM&R members report that increased neck strain and injury is common in many of the wheelchair users that they treat who do not have access power seat elevation. These individuals have to look up in order to engage in conversation with able-bodied individuals. This has notable downstream negative effects, including musculoskeletal disorders such as cervical radiculopathy, and encourages poor posture while seated in the power chair.

Many AAPM&R members who prescribe power seating systems also report the medical necessity of reach for independence in performing MRADLs at home for their patients. This patient population may otherwise be forced to rely on Home Health Care, which has limited coverage under CMS. This raises additional equity issues, as those who can afford to pay out of pocket for home aides will do so, and those who cannot are left without this necessary assistive technology and must rely on sporadic help or be forced into already limited and crowded nursing homes. This latter scenario is something that AAPM&R members unfortunately see all too often.

Group 2 Power Wheelchairs

AAPM&R strongly supports expanding coverage of seat elevation to include users of Group 2 power wheelchairs and appreciates that CMS has indicated they are considering moving forward on this front.

While the equipment and standards for Group 2 wheelchairs are different from Group 3, CMS beneficiaries using Group 2 power wheelchairs who need seat elevation should qualify for coverage under Medicare. The patient population that typically requires Group 2 wheelchairs typically includes people with cardiovascular and pulmonary conditions like congestive heart failure, osteoarthritis, amputees, and COPD. If mobility for these patients is limited to the point where seat elevation would be reasonable and necessary for their medical needs, they should not be excluded just because they don’t fit into the specific diagnoses under the Group 3 coverage criteria.

Seat elevation can help Group 2 power wheelchair users to perform MRADLs, particularly “sit to stand” transfers to and from their wheelchair. This patient population would see incredible benefits from being given coverage for seat elevation systems.

Conclusion

AAPM&R would also like to highlight that it is an active member of the Independence Through Enhancement of Medicare and Medicaid (ITEM) Coalition and wishes to associate itself with the comments submitted by the ITEM Coalition. The ITEM Coalition is a national consumer- and clinician-led coalition advocating for access to and coverage of assistive devices and technologies for persons with injuries, illnesses, disabilities, and chronic conditions of all ages. Given that many physiatrists treat patients who will benefit from increasing access to and coverage of these devices, AAPM&R is proud to be a member of the ITEM Coalition and fully supports their comments as submitted.

AAPM&R applauds CMS for recognizing the significant clinical evidence and overwhelming public support for covering seat elevation in CRT power wheelchairs and encourages the agency to quickly finalize a coverage decision that ensures all beneficiaries who can benefit from seat elevation are able to access this technology under the Medicare program.

If AAPM&R can be of further assistance on this request, please contact Chris Stewart, Director of Advocacy and Government Affairs, via email at cstewart@aapmr.org or via phone at 202-256-6580.

Prakash Jayabalan MD, PhD

Chair, AAPM&R Health Policy and Legislation Committee

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March 17, 2023

SUBMITTED ELECTRONICALLY

The Honorable Chiquita Brooks-LaSure
Administrator
Centers for Medicare and Medicaid Services
500 Security Boulevard
Baltimore, MD 21244

Re: Seat Elevation Systems as a Covered Accessory to Power Wheelchairs under the Medicare Program:CAG-00461N

Dear Administrator Brooks-LaSure:

As a person who has had extensive experience with wheelchair use, I write in my individual capacity to strongly support Medicare coverage of seat elevation in powers wheelchairs.I also serve as the Co-Coordinator of the ITEM Coalition, the organization that submitted the original NCD Reconsideration Request of Seat Elevation and Standing Systems in Power Wheelchairs.

I have personally never believed that CMS’s position that seat elevation is a convenience to the user held any weight and, frankly, found it offensive when some CMS staff and contractors referred to seat elevation as a “luxury item.”Assistive devices and technologies that enable a person to ambulate or be mobile enough to perform daily activities, whether inside or outside of the home, are certainly not conveniences or luxuries.They are medically necessary devices that accommodate for a loss in function due to illness or injury and they should have been considered “primarily medical in nature,” and therefore, covered durable medical equipment, many years ago.To think of the tens of thousands of Medicare beneficiaries over the past twenty years, and by extension, the millions of privately insured individuals whose health plans follow Medicare’s coverage policies, that endured the daily struggles of life in a wheelchair without seat elevation is sickening.What a missed opportunity for our nation’s largest health care program.

But today I applaud CMS for finally proposing to recognize seat elevation systems as primarily medical in nature and reasonable and necessary for beneficiaries who qualify for this benefit. While I strongly support Medicare coverage of seat elevation under the durable medical equipment (“DME”) benefit, I offer these comments in response to the proposed NCD and urge CMS to consider revising its decision as noted below to ensure that all Medicare beneficiaries who need access to power seat elevation systems will receive coverage for them.

As CMS prepares its final NCD for release in May 2023, the I urge the agency to:

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My name is Julie Piriano, and I am a licensed Physical Therapist in Illinois. I am also an ATP/SMS who has been involved in the provision of seating, positioning, and wheeled mobility devices for the past 39 years. I am also the Chair of the RESNA Professional Standards Board, was an author on the RESNA Position on the Application of Seat-Elevation Devices for Power Wheelchair Users Literature Update (Schiappa et al., 2019), and worked in collaboration with the principal Investigators at Georgia Tech research into the Everyday Use of Power Adjustable Seat Height Systems (Sonenblum et al., 2019). It is from this perspective that I respectfully submit my comments with regard to CMS’ proposed decision memo on seat elevation systems as an accessory to power wheelchairs.

When I was first introduced to seat elevation systems years ago I recognized that it doubled the functionality of the power wheelchair for my patients by providing access to the vertical environment for transfers, reach, and a visual line of sight that could not be achieved from a low, static seat height. I greatly appreciate the fact that CMS has recognized power seat elevation systems as durable medical equipment, has deemed them reasonable and necessary for Medicare beneficiaries, and will move forward with coverage of this enabling technology when certain conditions are met. However, I am concerned with the proposed conditions that must be met, as written and am also concerned that other medical benefits for power seat elevations systems were not considered or included, as outlined below.

Transfers
I completely agree with CMS that power seat elevation systems provide the wheelchair user with the ability to adjust the seat height of the wheelchair for transfers to and from their wheelchair using the transfer technique that safest and most effective for them. But, I am concerned that CMS’ review of the literature, as presented in the proposed decision memo, has resulted in a condition of coverage that is not accurately reflective of the evidence, or supported by subject matter expert consensus.

1. While it is assumed that CMS meant seat elevation is deemed reasonable and necessary to mitigate the challenges presented by non-level UPHILL transfers the question is –does it preclude coverage if the beneficiary elevates their seat to perform a non-level DOWNHILL transfer using a gravity assisted technique? Many Medicare beneficiaries elevate the height of their seat to a position that is slightly lower than the height of the surface they are transferring from (i.e., a hospital bed at 21” – 39” high) to perform a downhill, gravity assisted sitting transfer out of bed at the beginning of the day and then elevate it slightly higher than the same surface and use the same transfer technique to get into bed at the end of the day. I urge CMS to remove the words, “non-level (uneven)” from the proposed condition that must be met related to transfers so that individuals with disabilities are not precluded from having access to this medically necessary component when their safest, most effective method of transferring is using a non-level or uneven technique.

2. As a clinician who has transferred thousands of patients over the years, I am concerned that the term “weight-bearing transfers” lacks clarity, may be misinterpreted, and has different implications depending on the transfer technique, level of assistance, and equipment used. For example:

An individual may be “dependent” in their transfers to/from the power chair (meaning they are performing less than 25% of the task) using a sitting or standing technique due to the low, static seat height of the wheelchair. In this scenario their upper and/or lower extremities are still bearing weight, but they are relying on the assistance of a caregiver and/or assistive equipment to transfer. With a seat elevation system, the appropriate transfer method for them, and transfer training we often see these individuals perform a progressively greater percentage of the transfer task with a long-term goal of independence. I am concerned that a “dependent” transfer will be misinterpreted as a non-weightbearing transfer and therefore deny access to a medically necessary seat elevation system that would afford them the ability to perform or more actively participate in the transfer.

3. I applaud CMS for recognizing the importance of caregiver assistance with the transfer, when needed, but I am concerned that CMS’ example regarding the use of assistive equipment (e.g., sliding board, cane, crutch, walker) could be misinterpreted as excluding other assistive devices from being permitted for use during a transfer in order to meet the condition for coverage. There are a wide array of transfer assistance devices used by individuals with disabilities and complex medical needs such as, but not limited to, transfer handles on their wheelchair, a trapeze attached to the bed, a transfer pole that is positioned between the floor and ceiling, a transfer/pivot disk similar to a sliding board but with added capabilities, or a sit-to-stand device where the beneficiary is helped to a standing position with their feet on a platform instead of the floor. For clarification purposes I encourage CMS to consider one of the following changes:

1. Transfers may be accomplished with or without caregiver assistance and/or the use of mobility assistive equipment (e.g., cane, crutch, walker, etc.) and/or the use of transfer assistive equipment (e.g., sliding/transfer board, transfer handles, trapeze, transfer pole, transfer/pivot disk, sit-to-stand device, etc.), or
2. Transfers may be accomplished with or without caregiver assistance and/or the use of assistive equipment (e.g., sliding board, cane, crutch, walker, etc.).

4. I am also concerned that individuals with diagnoses such as ALS, MS, Muscular Dystrophy, Spinal Muscular Atrophy, and high-level tetraplegia due to a Spinal Cord Injury, who do not have the balance and/or core strength and postural control to transfer to/from their power wheelchair, and use a patient lift or transfer system, would be precluded from coverage consideration of a seat elevation system. As such I respectfully request CMS to consider this small subset of individuals when finalizing the conditions that must be met as they relate to transfers. I point this out because the transfer of these individuals includes the removal of the transfer sling once the person is seated in their PWC, and placed back under them before they are transferred out. The seat elevation system may be an essential component for this type of transfer to be fully executed safely as the beneficiary’s weight is shifted side to side in a seated position to remove/replace the sling.

Reach
As an author on the RESNA position paper on seat elevation devices who participated in an extensive review of the research in support of the application of this technology associated with reach biomechanics, safety and range I am deeply concerned that CMS did not include the application of seat elevation systems for the purpose of reach when making the determination as to what does and does not constitute a medical benefit for this power seating component. The evidence is clear that seat elevation devices are medically necessary to preserve shoulder, upper spine, and neck integrity during reaching activities from a seated position. Based on the data obtained by Georgia Tech on power wheelchair users with a seat elevation system, as captured by calibrated data loggers for seat height and in-seat activity, it was clearly shown that in-seat activity increased when the seat was elevated along the vertical continuum. While we did not know what activities the individuals in this cohort engaged in while elevated we do know that study participants reported that seat elevation provided a functional benefit on a daily basis. I respectfully request that CMS review the body of peer reviewed evidence that was submitted with the initial NCD Reconsideration Request submitted by the ITEM Coalition in September 2020, as well as the significant number of comments submitted by subject matter experts, and supported by patient-centered outcomes data submitted to the agency during the initial open comment period and this comment period. I also request that, upon review of the overwhelming evidence in support of the medical benefits derived from a seat elevation system, and in light of the mandate for mobility assistive equipment to permit Medicare beneficiaries to perform or obtain assistance to participate int heir MRADLs, that CMS revise the conditions that must be met for coverage consideration of a seat elevation system to include reach.

Visual Line of Sight
Having worked with thousands of patients who have a medical need for a power wheelchair I can say that the vast majority operate their chair with a joystick hand control and may use the seat elevation system to reach and function in their environments to perform or participate in their MRADLs. In this scenario seat elevation would provide an added benefit for the wheelchair user to have a better line of sight to the locations, surfaces, and objects they must reach and interact with. However, there is a small subset of individuals who either have upper extremity limb loss, or have a loss of function in their upper extremities and drive their power wheelchair with their chin, mouth, or head where the application of a seat elevation system serves a very different purpose as it relates to visual orientation and line of sight. For example, a young lady born with Tetra Amelia Syndrome (the absence of both arms and legs) drives her chair with a precisely placed control at her chin.
Without the use of a seat elevation system, she would be required to operate her PWC from a low, static seat height that does not give her visual access to her surroundings above her line of sight without looking up. Unfortunately, as soon as she looks up to gain visual access to the environments of use, including her home, she loses contact with the drive control device and the chair stops moving. As “drivers” we are taught to scan our environment as we move but the device we are operating (i.e., car, bicycle, wheelchair, etc.) does not stop unless the manner in which we operate it happens to be with the chin, mouth, or head. For this reason I respectfully request CMS consider this small subset of individuals with disabilities that use an alternative drive control system to be considered for coverage of a seat elevation system as a medical benefit as well.

Specialty Evaluation as a Condition for Seat Elevation to be Deemed Reasonable and Necessary
The second condition that must be met for coverage consideration of a seat elevation system is that “The individual has undergone a specialty evaluation by a practitioner who has specific training and experience in rehabilitation wheelchair evaluations, such as a physical therapist (PT) or occupational therapist (OT), that assesses the individual's ability to safely use the seat elevation equipment in the home.” As the Chair of the RESNA Professional Standards Board, and an ATP since 1997 I am particularly concerned that CMS has not proposed the provision of a seat elevation system to follow the same beneficiary safeguards that have been established for other power seat functions (i.e., power tilt and/or power recline) and include a provision that would require the seat elevation system to be provided by a supplier that employs a RESNA certified Assistive Technology Professional (ATP) who specializes in wheelchairs and who has direct, in-person involvement with the wheelchair selection for the beneficiary. The requirements to obtain and maintain certification as a RESNA certified ATP are stringent, include a statement of good moral character, and compliance with the RESNA Code of Ethics and Standards of Practice. This alone provides Medicare beneficiaries, the benefit, and the Medicare Trust Fund with a heightened level of trust that the provision of complex rehab technologies, such as power seat elevations systems, is protected as a violation of the Code of Ethics or Standards of Practice may result in the revocation of the ATP credential. I strongly urge CMS to apply the same criteria for coverage of a seat elevation system as are in place for power tilt and/or recline systems and require the seat elevation equipment be provided by a supplier that employs a RESNA certified ATP who specializes in wheelchairs and who is directly involved in the evaluation and recommendation of the seat elevation system.

Seat Elevation for Use on Group 2 Power Wheelchairs
CMS asked for comments on whether seat elevation equipment on Group 2 PWCs primarily and customarily serves a medical purpose and thus also falls within the benefit category for DME. I can say that in my years of experience in serving a wide array of individuals with mobility challenges and complex medical needs who have a medical need for a power wheelchair that seat elevation of at least 6 inches (as defined in the Wheelchair Options and Accessories Policy Article) serves a medical purpose, especially as it relates to transfers and I urge CMS to include seat elevation systems on a Group 2 power wheelchair within the benefit category. However, I would also say that most Group 2 power wheelchair users present very differently from Group 3 power wheelchair users, have different needs when it comes to the application of seat elevation, as well as different performance characteristic that might be defined by a complex rehab seat elevation system.

Thank you for your consideration of these comments.

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OHIO ASSOCIATION OF MEDICAL EQUIPMENT SERVICES

March 17, 2023
Via Electronic Submission to Medicare Coverage Database

Re: Administrative File: CAG-00461N; Comments on CMS Proposed Decision Memo: Seat Elevation Systems as an Accessory to Power Wheelchairs (Group 3)

The Ohio Association of Medical Equipment Services (OAMES) is pleased to offer comments on CMS’ proposal to include power seat elevation equipment on Group 3 power wheelchairs within the durable medical equipment (DME) benefit. OAMES is a non-profit state trade association that advocates access to quality DME services. The association’s membership includes a broad cross-section of the homecare community with local, regional and national HME providers as well as hospital-based organizations, pharmacies, manufacturers, distributors and various service vendor partners serving the DME and homecare sector.

OAMES is an active member of the American Association for Homecare (AAHomecare), the national voice of the DME provider community, and we work in close collaboration to advance state and federal policies for DME providers and consumers. As such, we fully support AAHomecare’s full comments outlined here which are summarized below:

1. Finalize the proposed Benefit Category Determination holding that power seat elevation systems are primarily medical in nature and are considered DME under the Medicare benefit; and finalize the proposed coverage determination holding that these systems are reasonable and necessary for Medicare beneficiaries who use Group 3 and above CRT power wheelchairs in order to perform transfers for the purpose of performing or participating in mobility related activities of daily living (MRADLs);
2. Include coverage for Medicare beneficiaries who need seat elevation to improve their reach and line of sight to support shoulder, upper spine, and neck integrity while performing or participating in MRADLs;
3. Include coverage of seat elevation for Medicare beneficiaries who use Group 2 CRT power wheelchairs in the final NCD; and
4. Provide important clarifications to the proposed NCD, including further detail regarding “weightbearing transfers,” beneficiaries using patient transfer devices, and the specific criteria for specialty evaluations.

Thank you for the opportunity to provide comments. Our members are proud to be part of the continuum of care that assures Medicare beneficiaries receive cost-effective, safe and reliable home care products and services. Your consideration is greatly appreciated. Please contact me at kam@oames.org if you have any questions.

Sincerely,

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My name is Omotola Emmanuel, and I'm a Doctoral Occupational Therapy Student(OTS) at Saint Joesph's University and an advocate for individuals with disabilities. As an OTS, I have had the opportunity to learn about the unique accessibility features that power wheelchairs provide and all that encompasses acquiring a wheelchair for clients. Today I am writing this letter to you to advocate and support the inclusion of seat elevation and power standing systems in Medicare coverage.

The power seat elevation and power standing systems on power wheelchairs are essential for people with mobility limitations. All individuals have the right to engage in various healthy and meaningful occupations. When that right is denied, it is referred to as occupational injustice (Durocher et al., 2014). To combat these injustices, we as a society must work together to help provide equity and fairness for individuals, groups, and communities by offering resources and opportunities for engagement in their occupations. Regarding wheelchair accessibility, studies have shown that all aspects of the wheelchair and seating provision process impact occupational performance, equality of opportunity, and community mobility (Gowran et al., 2022. Allowing power wheelchair users to elevate their seats and stand can not only open up opportunities for these individuals to improve their engagement in various meaningful activities such as social participation and activities of daily living (ADLS ), but also improve their overall quality of life. Future and current health professionals and providers must do their due diligence to review their practice and service provision systems so that individuals with mobility impairments can meet their individualistic and essential needs.

Therefore, I thank medicare for doing their due diligence by allowing members of our society to submit comments on our support for the medicare proposal. We look forward to your timely response on finalizing the coverage for seat elevation and standing systems to ensure occupation justice so that wheelchair users can access the care they need.

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March 17th, 2022

SUBMITTED ELECTRONICALLY VIA Medicare Coverage Database Portal

The Honorable Chiquita Brooks-LaSure
Administrator
Centers for Medicare and Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

Re: CAG-00461N: Seat Elevation Systems as an Accessory to Power Wheelchairs

Dear Administrator Brooks-LaSure:

In service of the neuromuscular disease (NMD) patient community, the Muscular Dystrophy Association (MDA) thanks the Centers for Medicare and Medicaid Services (CMS) for the opportunity to comment on CMS’s national coverage redetermination (NCD). We are grateful for CMS’s proposal to cover seat elevation systems for Group 3 wheelchairs, as these features are vital for our constituents' health, safety, and independence. Additionally, however, we urge CMS to consider extending coverage for the purposes of reach and line of sight needs in addition to weight-bearing transfers and specialty evaluations, and to extend coverage to group 2 wheelchairs.

MDA is the nation’s leading nonprofit organization dedicated to empowering the lives of individuals living with neuromuscular diseases through innovations in science and innovations in care. MDA fulfills its mission by funding biomedical research, providing access to expert clinical care and support through its national MDA Care Center Network, and championing public policies and programs that benefit those we serve. Since its inception, MDA has invested more than $1 billion in research grants to accelerate treatments and cures for neuromuscular disorders, making MDA the largest source of neuromuscular disease research funding in the U.S. outside of the federal government.

Background:

Neuromuscular diseases affect individuals’ muscles, limbs, and mobility and often lead to reliance on a wheelchair or other assistive mobility device. To completely address the loss of function that results from mobility-related disabilities, we encourage CMS to acknowledge the full range of functional loss. People who qualify for complex rehab power wheelchairs classified as Group 3, as well as those that use Group 2 chairs, require the use of their wheelchair for all activities throughout the day. The reduced mobility brought on by wheelchair use has many effects on those with neuromuscular diseases. Most notably, there are a large number of health effects that stem from using a wheelchair. See generally, Caulton, et. al. A randomized controlled trial of standing programme on bone mineral density in non-ambulant children with cerebral palsy, ARCHIVES OF DISEASE IN CHILDHOOD, 89(2), 131-35. Additionally, using a wheelchair results in reduced mobility and presents obstacles to self-sufficiency as well as safety concerns. See generally, Arva et. al. RESNA Position on the Application Seat-Elevating Devices for Wheelchair Users, https://www.rstce.pitt.edu/RSTCE_Resources/Resna_position_on_seat%20elevation.pdf [hereinafter, RESNA Position] Due to these limitations and the consequences therein, it is essential that CMS provide coverage for these features.

The benefit of Seat Elevation Technologies:

The medical issues posed by standard wheelchairs outlined above are all significantly ameliorated by seat elevation systems. Newman et. al. The effect of supported standing in adults with upper motor neurone disorders: a systematic review, Rev 26(12):1059–1077. See also generally, Arva et. al RESNA Position. CMS has received many peer-reviewed articles from other organizations that will provide considerably more data on the many additional benefits of seat elevation systems, including the benefits for improved circulation, mobility, gastrointestinal health, range of motion, promotion of vital organ capacity, improved bone density, and reduced occurrence of skin ulcers and skeletal deterioration. Id. Given the data provided to CMS, it is clear that coverage of these devices is medically necessary. In addition to the medical necessity of these devices, we would like to draw CMS’s attention to the fact that seat elevation systems vastly improve users’ ability to perform daily living activities such as bathing, cooking, and cleaning more safely and with less physical strain which only furthers the health of users. Herberts et. al. Shoulder pain and heavy manual labor, CLINICAL ORTHOPAEDICS & RELATED RESEARCH, 166-78. See also, Palmerud et al. Intramuscular pressure of the infra- and supraspinatus muscles in relation to hand load and arm posture, EUROPEAN JOURNAL OF APPLIED PHYSIOLOGY Rev. 83, 223-30 [hereinafter, Intramuscular pressure]. Finally, seat elevation systems make transfers in and out of seats vastly safer and less physically costly. Id. Not only does this ease of transfer help with the quality of life of users generally, but also, safe transfer makes travel considerably more accessible. This accessibility for travel is particularly important for members of the NMD community as traveling to see medical specialists across the country is common.

In light of these benefits, we believe CMS should expand its coverage determination to include those that would benefit from increased reach and line of sight. CMS limited its evidence review to only clinical studies regarding transfers. National Coverage Analysis Proposed Decision Memo, Centers for Medicare and Medicaid Services, Seat Elevation Systems as an Accessory to Power Wheelchairs (Group 3) (Feb. 15, 2023). https://www.cms.gov/medicare-coverage-database/view/ncacal-decision-memo.aspx?proposed=Y&NCAId=309 However, as can be seen in the data provided in this comment, and in the many others submitted by healthcare providers and other patient advocacy organizations, there is extensive data to show that there are both medical benefits and benefits to mobility-related activities of daily living (MRADLs) associated with increased ability to reach and adjust neck positioning. See generally, Palmerud et. al. Intramuscular pressure. Based on this evidence, it is abundantly clear that the medical value provided by seat elevation systems for reach and line of sight meets the reasonable and necessary standard required.

The Benefit of Seat Elevation Technologies in Group 2 Wheelchairs:

In addition to covering seat elevations for the purposes of reach and line of sight, MDA is grateful for CMS’ consideration of expanding coverage for seat elevation systems to Group 2 wheelchairs and would encourage CMS to do so. Many in the NMD community, those living with Inclusion Body Myositis and Myasthenia Gravis, for example, are candidates for Group 2 wheelchairs, and would benefit greatly from standing just as those who use Group 3 wheelchairs, such as those living with Amyotrophic lateral sclerosis (ALS) and Muscular Dystrophy would. The benefits of seat elevation systems for those that use Group 2 wheelchairs are similar to the benefits for those that use Group 3 wheelchairs. Seat elevation systems would provide all of the medical benefits listed above, as well as assist with MARDLs and reduce strain during “sit to stand transfers”. See generally, Palmerud et. al. Intramuscular pressure. See also generally, Arva et. al. RESNA Position. Many in the NMD community are deemed a high fall risk and experience falls when standing, or attempting to stand, while performing MARDLs. See, Berends et. al. High incidence of falls in patients with myotonic dystrophy type 1 and 2: A prospective study,

NEUROMUSCULAR DISORDERS, Vol. 29, Issue 10, 758,758-65, Oct. 2019. As above, given the medical benefit of seat elevation and the risk of harm while performing transfers and/or MARDLs, it is clear that the benefit to those that use Group 2 wheelchairs rises to the reasonable and necessary standard required.

Request for clarification:

MDA seeks clarification in the following areas with regard to the text of the NCD to ensure that future Local Coverage Determinations (LCDs) do not come into conflict with the intent of CMS’ NCD.

Clarification on the meaning of “weight-bearing transfers”

The proposed decision memo states that power seat elevation can be found to be reasonable and necessary for beneficiaries who perform “weight-bearing transfers” to and from their power wheelchair within the home. The coverage criteria states that this can include the use of upper extremities for non-level sitting transfers and/or the use of lower extremities during a sit-to-stand transfer and can be supported with or without caregiver assistance. However, the decision memo is then silent as to its intended definition, and limitations therein, of the term “weight-bearing transfer.” National Coverage Analysis Proposed Decision Memo, Centers for Medicare and Medicaid Services, Seat Elevation Systems as an Accessory to Power Wheelchairs (Group 3) (Feb. 15, 2023). https://www.cms.gov/medicare-coverage-database/view/ncacal-decision-memo.aspx?proposed=Y&NCAId=309 This definition may exclude those that perform dependent transfers as they cannot assist with their own transfers by bearing their own weight. Given that all transfers to and from a wheelchair require weight to be borne somewhere, all transfers are weight bearing transfers. Additionally, those that perform dependent transfers will still medically benefit from a seat elevation system’s assistance with performing MRALDs, meeting the standard laid out by the NCD.

Therefore, we request that CMS clarify this term to ensure that all individuals who would benefit from transfers are included in coverage, and particularly those that perform dependent transfers, are not precluded from accessing seat elevation systems.

Clarification on treatment of beneficiaries who use patient transfer devices

Similarly, CMS states in it’s proposed decision memo that “[t]ransfers may be accomplished with or without caregiver assistance and/or the use of assistive equipment (e.g. sliding board, cane, crutch, walker).” Id. While this list is not exhaustive, we did take note of CMS’ lack of language to open the list, and the lack of more advanced assistive technologies, such as patient transfer devices that may be mounted to the floor or ceiling to assist with patient transfers. As with those that rely on a caregiver for a dependent transfer, patients that use devices such as mounted mechanical lifts would still benefit from seat elevation systems to perform MRALDs and when transferring to a surface in their home that is not accessed by their mounted mechanical lift.

We encourage CMS to clarify that patient transfer devices such as mounted lifts are included in the intended definition of “assistive technology” used in the proposed decision memo and that the use of such devices should not preclude a beneficiary from otherwise qualifying for coverage.

Conclusion:

MDA is committed to ensuring that individuals with neuromuscular diseases have access to devices to promote safe and healthy lives. We encourage CMS to provide coverage for seat elevation systems.

We appreciate this opportunity to provide comment on CMS’s national coverage redetermination. For questions regarding MDA or the above comments, please contact me at 336-409-4000 or jcartner@mdausa.org.

Sincerely,

Joel Cartner, Esq.
Director, Access Policy
Muscular Dystrophy Association

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The Boston Center for Independent Living’s mission is to promote greater independence for people with disabilities and support full integration into society. A significant number of our staff and the members we serve are wheelchair users with a wide variety of needs. BCIL fully supports the Centers for Medicare and Medicaid Services’ proposed regulation that would allow power seat elevation equipment on Group 3 power wheelchairs to fall within the benefit category for durable medical equipment. Elevation equipment is a necessity for several of our staff and members to perform tasks of daily living such as cooking safely without risking burns, cleaning, reaching a top shelf in the refrigerator or looking through their house door peephole. Elevation equipment also has countless other benefits such as allowing for safe and level transfers that lessen impact on the upper body or enabling eye-level engagement that evens the playing field.

We strongly encourage CMS to also cover seat elevation on Group 2 wheelchairs. Some people with good function do not qualify for a group 3 chair, yet struggle with transfers and activities of daily living that are essential for self-reliance.

Finally, BCIL recommends that CMS support coverage of standing accessories on wheelchairs by recognizing their medical benefit. Standing provides pressure relief, which prevents a range of injuries, enhances blood circulation and promotes a healthy bone density amongst other obvious medical benefits.

We believe that all those changes would enhance the independence, dignity, and quality of life of people with disabilities.

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Please consider coverage for power seat elevation. It is crucial for disabled individuals to perform their activities of daily living.
Take a moment to consider doing activities around the house in a seated position. Can you reach food in the cabinets? Use the microwave? Access your bathroom cabinets and sink? What about crossing a parking lot in a seated position?.....very dangerous.
Although CMS doesn't seem to recognize that humans have activities outside the home, imaging the social aspect of looking people in the eye when communicating versus looking at their waist or looking up all the time. Go out to eat and sit at a high top table in a normal chair...it just doesn't work. If we want to provide a full life of activity and function to non ambulatory individuals, this is a crucial component of function. The data is there. We have collected information on this in regards to requests, denials, and approvals. I have personally been involved in hundreds of applications of power seating through the Veterans Administration (as they have the understanding and ability to prescribe and fund this) and the successes and lifestyle enhancements we hear from these Veterans is incredible. Please pass coverage for elevate and standing features on power mobility.

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These comments are submitted on behalf of the Rehabilitation Engineering and Assistive Technology Society of North America (RESNA) in response to the Centers for Medicare and Medicaid Services (CMS) public comment period on “Seat Elevation Systems as an Accessory to Power Wheelchairs (Group 3) (CAG-00461N)- Proposed Decision Memo.”

RESNA strongly supports CMS’ recognition of power seat elevation systems as primarily medical in nature. We understand this acknowledgement which leads to the benefit category decision of DME is a required step toward establishing Medicare coverage of this technology.

RESNA appreciates the opportunity to submit comments regarding the CMS proposed decision regarding seat elevation systems. RESNA is the premier professional membership organization dedicated to promoting the health and well-being of people with disabilities through increasing access to technology solutions. RESNA’s members represent researchers, educators, academia, clinicians and others focused on the field of Assistive Technology (AT) and Rehabilitation Engineering (RE). As an organization, RESNA is particularly focused on activities that improves professionalism, advances education, and encourages research in assistive technology, which includes wheelchairs and wheelchair seating.

RESNA was a supporter of the request for reconsideration submitted by the Independence Through Enhancement of Medicare and Medicaid Coalition (ITEM) which included power seat elevation and power standing for Group 3 and above PWCs. RESNA encourages CMS to move quickly to open the review of power standing.

For the purposes of our comments associated with coverage of power seat elevation, RESNA will focus on areas where the expertise of our members and RESNA may be unique. As collaborators on the initial request, we also support the comments of ITEM, and the Clinician Task Force (CTF).

Our comments will address the following aspects associated with the CMS proposed policy: 1) Coverage of power seat elevation for use on Group 3 power wheelchairs (PWCs), 2) Coverage of power seat elevation for beneficiaries using Group 2 PWCs, 3) Additional efforts needed to effectively implement NCD Changes, 4) Technology Concerns.

Coverage of Seat Elevation on Group 3 PWCs

The decision summary in the Decision Memo for Mobility Assistive Equipment CAG-00274N (2005) states, “The development of an assessment in support of Medicare coverage decisions is based on the same general question for almost all requests: Is the evidence sufficient to conclude that the application of the technology under study will improve final health outcomes for Medicare patients?” (p. 5).

Based on Medicare’s perspective of improving health outcomes and definition of medical necessity, it isn’t clear why the evidence question in the current proposed decision (p. 12) specifically refers to transfers only. RESNA asserts that the question should consider seat elevation’s impact on health more broadly than transfers only. Instead, consideration should be given to whether the evidence is sufficient to conclude that the use of power seat elevation systems will improve the final health outcomes for Medicare patients. Based on research articles identified in the initial ITEM NCD change request, a comprehensive review of the evidence would demonstrate the positive impact of power seat elevation systems on beneficiary outcomes related to transfers, reach, and line of sight. In addition, like the 2005 NCD for MAE related to PMDs, seat elevation also improves the beneficiary’s ability to perform or participate in activities of daily living, termed by CMS as MRADLs. Coverage of seat elevation technology should be based on a full review of the evidence regarding its impact on health outcomes.

RESNA strongly encourages CMS to approve coverage of seat elevation at the NCD level and utilize the LCD process to determine more detailed coverage criteria that would be based on medical and functional needs.

The proposed coverage criterion regarding “weight-bearing transfers” requires additional clarification. The proposed policy states, “Transfers may be accomplished with or without caregiver assistance and/or the use of assistance equipment (e.g. sliding board, cane, crutch, walker).” This is stated in a way that indicates that the equipment are just examples, and that other equipment could be used as well. However, because of the statement regarding “weight-bearing,” it does leave a question about whether the policy would allow WPC users who require a mechanical lift for transfers qualify for seat elevation. If not, this policy would leave a small, but vulnerable population of beneficiaries without access to this important technology, specifically, beneficiaries with quadriplegia, ALS, and other diagnoses who are not able to perform lateral transfers.

People with permanent disabilities, and especially those with the diagnoses allowing coverage of Group 3 PWCs, are limited to the height of the power wheelchair seat height for performing all tasks. Therefore, without power seat elevation, the power wheelchair base itself becomes a barrier that prevents the user from accomplishing ADLs, and in certain situations and tasks, places the beneficiary at heightened risk of morbidity or mortality secondary to the attempts to perform tasks.

For example, and similar to risks associated with wheelchair transfers, repetitive strain injuries occur due to overhead reaching. The range of functional reach is also an issue for beneficiaries qualifying for Group 3 PWCs due to limited range of motion and strength. Additionally, these PWC users are at high risk of falls when reaching beyond their base of support to perform tasks from the lower seat height of their PWC.

Considering the population of beneficiaries who qualify for Group 3 PWCs, they are also at higher risk of skin injury. Skin integrity deteriorates when there is an inability to reach a sink or items needed for grooming and personal hygiene.

Still focused on the population of beneficiaries who qualify for Group 3 PWCs, the ability to reach food and drink at will, and not waiting until someone is available to provide it, is of critical importance. Healthy eating and hydration is essential for all Medicare beneficiaries, but can be life threatening for certain people with disabilities. Malnutrition and dehydration are factors in skin health, already a high risk for this population of wheelchair users, but are also indicators of overall health and can impact disease progression as well. This is supported by evidence associated with person diagnosed with ALS. Independent access to food and drink is facilitated by power seat elevation technology.

Additionally, risk increases for beneficiaries handling hot pots and pans, and removing pots containing hot food or boiling water from a stove or cooktop can be extremely dangerous and increases the risk of burns when performed from a low static seat height. This issue is related to reach and line of sight. Risk is caused by limited reach and line of sight from the static seat height of a PWC. It is impossible to view the inside of a pot from the limited height. It is also difficult to lift a pot from the stove from the PWC seat height, especially when range of motion and strength are already limited by disease or injury.

Line of sight, while typically considered as a social consideration or a means to facilitate eye-to-eye communication, is critical for performing all tasks that occur above the height of a person in a PWC. The frequent need to look up causes neck strain and pain for PWC users. Seat elevation technology allows the seat height to be adjusted to perform tasks at a functional height thereby reducing painful and harmful neck strain. (Diebo, B., Challier, V., Henry, J., Oren, J., Spiegel, M., Vira, S., Lafage, V. (2016). Predicting cervical alignment required to maintain horizontal gaze based on global spinal alignment. Spine, 41(23), 1795-1800.)

The ITEM formal request contained numerous references, including the "RESNA Position on the Application of Seat-Elevation Devices for Power Wheelchair Users" published in 2019, that provide evidence of the more extensive health outcomes related to seat elevation technology.

To conclude, RESNA considers the review of the evidence to be inappropriately limited to wheelchair transfers. Even if CMS has determined that the performance or participation in activities of daily living (ADLs) is not medically necessary, which seems counterintuitive given a primary reason for coverage in the NCD for MAE specific to wheelchairs is stated to be to perform or participate in MRADLs. Repetitive movement in the vertical plane related to reach and line of sight have an equally important impact on body structures as transfers. RESNA encourages CMS to complete a comprehensive review of the evidence related to reach, line of sight and other health outcomes associated with power seat elevation. After a comprehensive review of the literature, we believe that CMS will find reason to expand the recommended coverage of power seat elevation for use on Group PWCs.

Coverage of Seat Elevation on Group 2 PWCs

RESNA encourages CMS to cover seat elevation technology for any Medicare beneficiary who qualifies for a power mobility device and has a medical need for seat elevation. There is evidence that indicates a high risk of falls for beneficiaries with mobility limitations can occur during transfers regardless of whether the transfer is lateral or sit to stand.

The LCD for PMDs distinguishes beneficiaries who qualify for coverage of Group 2 PWCs strictly based on their diagnosis. However, there are some beneficiaries who have medical and functional needs for power mobility and seat elevation whose needs are similar to those who qualify for Group 3 PWCs. This makes development of a coverage policy for seat elevation challenging. RESNA believes evidence and medical need should be the basis for coverage, not groups of diagnoses associated with PWC groups.

Additional Efforts Needed to Effectively Implement NCD Changes Related to Power Seat Elevation Technology

Local Coverage Determination (LCD) Revision

The proposed policy requires that the individual has undergone a specialty evaluation by a practitioner who has specific training and experience in rehabilitation wheelchair evaluations, such as a physical therapist (PT) or occupational therapist (OT), that assess the individual’s ability to safely use the seat elevation equipment in the home. This criterion is similar to a criterion for coverage for other power seating systems, i.e., power tilt and power recline. RESNA supports the requirement, but encourages CMS to include the specialty evaluation and add the requirement of a RESNA-certified Assistive Technology Professional (ATP) for power seat elevation as established for other power seating systems as follows:

1. A specialty evaluation that was performed by a licensed/certified medical professional, such as a physical therapist (PT) or occupational therapist (OT) or practitioner who has specific training and experience in rehabilitation wheelchair evaluations of the beneficiary’s seating and positioning needs. The PT, OT, or practitioner may have no financial relationship with the supplier; and

2. The wheelchair is provided by a supplier that employs a RESNA-certified Assistive Technology Professional (ATP) who specializes in wheelchairs and who has direct, in-person involvement in the wheelchair selection for the beneficiary.

RESNA encourages CMS not to include these criteria as part of the NCD, but instead have the detailed coverage criteria included in a revision of the LCD for wheelchair options and accessories. Best practice may change over time, and revisions to an LCD will more readily allow policy to keep pace.

Technology Concerns

Coverage of wheelchairs, wheelchair accessories, and wheelchair seating conflate implementation of policy changes due to the National Coverage Determination (NCD), Local Coverage Determinations (LCDs), Policy Articles (PAs), and coding guidelines and requirements. RESNA recognizes that comments on these various policies may be considered to be outside the scope of this decision, however, we are providing general comments as we believe appropriate access to this important technology may require revisions to other related policies.

Power seat technology has changed in important ways over the last two decades. Some power seat elevation technologies have features that are designed specifically to meet the more extensive needs of people with permanent disabilities and who are dependent on this technology to facilitate transfers, as well as reach and line of sight, which requires a greater range of elevation. In addition, some people with permanent disabilities may also require power seat elevation to be combined with other power seating systems. These devices are different from basic seat elevation, in terms of the features and function designed to meet the needs of beneficiaries, but also in terms of the performance requirements associated with dynamic stability performance of the power wheelchair base.

RESNA believes that addressing coverage based on coding and classification of technologies available prior to 2005 is problematic. Specifically, the LCD associated with Power Mobility Devices (PMD) limits coverage to Group 3 PWCs as, “The beneficiary's mobility limitation is due to a neurological condition, myopathy, or congenital skeletal deformity.” This relegates beneficiaries without these diagnoses to Group 2 devices regardless of their medical needs or functional presentation.

The RESNA Assistive Technology Standards Board (ATSB) (resna.org/AT-Standards) coordinates the development of voluntary consensus standards in the United States and represents the needs and views of U.S. stakeholders in international standardization forums. The ATSB is the U.S. Technical Advisory Group to the American National Standards Institute (ANSI) for the development of international standards through the International Organization for Standardization (ISO) pertaining to assistive technology and other products for persons with disabilities. The RESNA Standards Committee on Wheelchairs (WCS) worked closely with the Statistical Analysis Durable Medical Equipment Regional Carrier (SADMERC) to evaluate and establish testing and product performance requirements. At that time, it was stated that it was necessary to be able to code all PWCs currently available. Changes in technology, increased knowledge regarding performance limitations garnered from testing performed by independent test labs, discontinuation of myriad PWC models, reductions in reimbursement causing a reduction in available wheelchair features. There are some HCPCS codes that today no longer have products that meet the requirements, yet coverage policy limitations do not allow access to current technology.

RESNA encourages CMS to cover seat elevation based on medical need, not the type of PWC the beneficiary qualifies for based on the current PMD LCD.

CMS instructs beneficiaries they must qualify for a PWC based on their needs inside their home, but use of the wheelchair outside their home is allowed. Depending on the environments a beneficiary routinely encounters, use of some power wheelchairs outside the beneficiary’s home may not be safe due to obstacles, inclines, or range. Related to seat elevation, RESNA is particularly concerned with the impact seat elevation, and the combination of seat elevation and other power seating systems have on dynamic stability of power wheelchairs. (RESNA ISO 7176-2 Wheelchairs – Part 2: Determination of dynamic stability of electric wheelchairs). The addition of these power seating systems alters the center of gravity. Performance requirements for all Group 2 PWCs, even those classified as CRT only require dynamic stability on an incline of 6 degrees. We encourage CMS to consider whether this is sufficient for Medicare beneficiaries who require seat elevation, and seat elevation combined with additional power seating systems. At a minimum, RESNA encourages CMS to require proof of dynamic stability testing of PWC bases with power seat elevation attached based on ANSI-RESNA standards, even if the base is already on the DMEC Product Classification List.

In the proposed NCD policy, it is stated, “CMS has not undertaken a significant review of these technologies in rulemaking or by an NCD since 2006.” RESNA recommends CMS take this opportunity to work with stakeholders to undertake a thorough state of the technology review of power wheelchair bases and power seat elevation, and consider changes to coding, code requirements, and performance requirements for PWCs that can accommodate power seat elevation devices with seat elevation range that exceeds 6 inches, and those that can be combined with other power seating systems. RESNA’s Wheelchair Standards Committee is willing to assist or provide additional advice related to these concerns.

Sincerely,

Carmen DiGiovine, PhD, ATP/SMS, RET
President, RESNA Board of Directors
Rita Stanley
Chair, RESNA Government Affairs Committee

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My current Permobil power wheelchair is 3 years old and has an elevating seat on it. When this feature was ordered, I had limited understanding of how useful it would become in my daily life. I envisioned the seat would enable me to reach into high kitchen cabinets. I do have some ability to stand and reach high places, however, this is not always safe for me to do as my standing balance is precarious. Reaching In a seated position is often the safest way to access things in higher locations. A potential fall from the standing could result in serious injury, requiring insurance coverage for a preventable injury.

Over the last 3 years, I have discovered many valuable uses of the elevated seat. When I am in an audience and my view is blocked by something structural or someone’s head, I can elevate the seat to the point I gain a clear view. When something is posted high on a wall or a pole, I can elevate the seat to be able to read whatever is at that height. In the kitchen, I can raise my seat to get above the kitchen sink in order to see and work inside of it. The ability to raise the seat is also helpful to raise above my air fryer so I see what I am doing down inside and keep my arm at a safe distance from the hot edges of it so I do not get burned.

I hope what I have written will help insurers understand an elevated seat is not a luxury. It is a device that helps people be more independent in their lives by being able to reach above their heads in a seated position. Many people who use wheelchairs have no ability to stand. Other people who can stand, may run the risk of losing balance by standing to reach a high place, are spared injury by using an elevated seat.

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Seat elevation systems are critical for everyday safety for wheelchair users! In addition to preventing falls/injuries during transfers, seat elevation supports improved postural alignment, an important consideration for reducing chronic problems resulting from poor positioning (aka constantly looking up to interact with the environment and other people) And lastly elevation systems allow for increased independence during daily tasks.

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Dear Administrator Brooks-LaSure:

I write to express my strong support for the Centers for Medicare and Medicaid Services’ (“CMS's”) proposed National Coverage Determination (“NCD”) for seat elevation systems in Complex Rehabilitation Technology (“CRT”) power wheelchairs. CMS should finalize the proposed Benefit Category Determination that power seat elevation systems are primarily medical in nature and are considered durable medical equipment under the Medicare benefit. CMS should also finalize the proposed coverage determination holding that these systems are reasonable and necessary for Medicare beneficiaries who use Group 3 CRT power wheelchairs in order to perform transfers for the purpose of performing or participating in mobility related activities of daily living ("MRADLs"). The final NCD should (1) include coverage for Medicare beneficiaries who need seat elevation to improve their reach and line of sight to support shoulder, upper spine, and neck integrity while performing or participating in MRADLs; and (2) include coverage of seat elevation for Medicare beneficiaries who use Group 2 CRT power wheelchairs in the final NCD. Lastly, I strongly encourage CMS to open the public comment period for standing systems in CRT power wheelchairs as soon as possible.

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With progressive loss of mobility in childhood, Duchenne Muscular Dystrophy (DMD), is the most common inherited neuromuscular disease in boys. Not only do individuals with DMD experience social and community disengagement due to declining physical ability, they also may experience secondary disabilities from prolonged sitting such as, genitourinary problems, chronic pain, and orthopedic complications. Aside from physical disabilities, a lack of participation in everyday life situations can lead to difficulty with feeling competent, motivation, self-efficacy, and self-determination. Ultimately, this can lead to secondary mental health problems, as well.

Handicapped children may develop a poor sense of self-efficacy due to lack of ability or access to participate in everyday activities compared to peers. From a social development perspective, a key to self-efficacy is social acceptance by peers and teachers and mutually beneficial social interactions(Gresham 1984). One of the four major sources of information for expectations of personal efficacy or competence is performance accomplishments(Gresham 1984). Personal accomplishments are based on personal mastery and repeated success in any situation increases self-efficacy. It is important for all individuals to build self-efficacy early on to support social development, as well as self-identity. The use of powered wheelchair standing devices(PWSDs) in young boys with DMD was assessed at home and in school. The study found that supported standing in a PWSD allowed the boys to achieve the participation goal of independent toileting during a time when they would typically need assistance. Additionally, an important motivator appeared to be the boy's desire for social engagement to “keep up” with peers in active physical activities (Young, Bray, McKinnon, Burns 2021). Having access to supported standing in PWSDs for non-ambulatory boys may increase equality and connection to peers as specified by comments from the subjects of the study such as, “I feel l am less invisible when I can stand,” and, “standing makes people want to talk more to me.”(Young et al. 2021). Being handicapped should not anticipate a lack of social participation, decreased participation in physical activities, or decreased self-efficacy.

It is each and every one of our rights as people to occupational justice. The lack of PWSDs for our handicapped community is allowing occupational injustice for many in the communities, especially children during a very important time of social development and discovery of one’s self. Not only is the lack of access to PWSDs promoting occupational injustice, but also a future of possible increased mental health and physical disability. It is crucial these children and everyone in the handicapped community have the access to stand and participate in everyday activities that essentially make up our lives if they choose to.

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Having a seat elevator on my wheelchair has made such a difference in the lives of me and my caregivers. Being able to raise my chair before transferring to/from my chair means less stress and strain on my caregivers' bodies. Less strain on a caregiver's body is extremely important. They should not be risking injury as part of their job. Fewer injuries to caregivers is also extremely important to clients like myself. For people with complex medical conditions like myself, anytime a caregiver misses a shift and medical needs go unmet it can quickly result in serious and long lasting negative effects on our health.

Besides the stated reasons for approving seat elevators, they have a positive impact in so many other ways. Reaching light switches, cabinets, elevator buttons, automatic door opener buttons etc greatly improves independence. Also, the ability to talk with somebody at eye level cannot be overstated. Mental health is far too often overlooked and I cannot overstate the impact having a seat elevator has had on my mental health by giving me a greater sense of independence and equality.

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I am excited that CMS has taken the opportunity to include power seat elevation as a necessary power seat function for group 3 power chairs. This is a technology that has been recognized as medically beneficial by the complex rehab community for quite some time; and the technology has continued to evolve to dramatically improve function and safety. As a prescribing clinician, there are countless examples of how power seat elevation has, not only improved independence, but also reduced the risk of repetitive stress injury by reducing the need to reach overhead, and power seat elevation has improved mental health of people who utilize group 3 power chairs, by allowing them to do more and allowing them the opportunity to talk to people who are standing face to face. Power seat elevation also improves client and caregiver safety with transfers.

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March 17, 2023

The Honorable Chiquita Brooks-LaSure
Administrator
Centers for Medicare and Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

SUBMITTED ELECTRONICALLY VIA Medicare Coverage Database

Re: CAG-00461N: Seat Elevation Systems as an Accessory to Power Wheelchairs

Dear Administrator Brooks-LaSure:

The Association of Rehabilitation Nurses (ARN) – representing approximately 4,500 rehabilitation nurses and more than 14,000 Certified Registered Rehabilitation Nurses (CRRN) that work to enhance the quality of life for those affected by physical disability and/or chronic illness – appreciates the opportunity to comment on the Centers for Medicare and Medicaid Services’ (CMS) proposed National Coverage Decision (NCD) for seat elevation systems in Complex Rehabilitation Technology (CRT) power wheelchairs. ARN supports all efforts to ensure persons with disabilities and chronic illnesses have access to the appropriate level of rehabilitation services to maximize functional outcomes, independence, and quality of life.

Rehabilitation nurses play many roles – Rehabilitation nurses work with patients of all ages, and their families or caregivers, soon after the onset of a disabling injury or chronic illness. They restore patients' lives, so they have freedom and independence again. They are collaborators, educators, care coordinators, advocates, and change agents. They work with other healthcare team members including physiatrists, occupational therapists, physical therapists, neuropsychiatrists, speech therapists, and many more specialists to create comprehensive care plans based on patient goals and maximum potential.

ARN applauds CMS for proposing to determine that seat elevation systems in Group 3 power wheelchairs are primarily medical in nature and are classified within the Durable Medical Equipment (DME) category. This is the first time Medicare has recognized these systems as DME and we commend CMS for this proposal. The NCD also proposes that these systems are reasonable and necessary for Medicare beneficiaries using Group 3 power wheelchairs when they: (1) perform weight-bearing transfers in the home to/from their wheelchair, with or without the use of caregiver assistance or assistive technology; and (2) undergo a specialty evaluation by a practitioner with specific training and experience (e.g., physical and/or occupational therapists) in rehab wheelchair evaluations. ARN strongly supports the proposed decision, which would increase access to this critical technology for beneficiaries who spend all or most of their time in a Group 3 chair. We believe this will be incredibly valuable for the disability community and will help to advance health equity in the Medicare population.

While we do support this proposal and appreciate CMS’ intent, ARN respectfully requests that CMS consider two additional inclusions for coverage. First, we recommend that CMS expand coverage to include reach and line of sight to support shoulder, upper spine, and neck integrity. Specifically, CMS should include coverage for Group 3 wheelchair users who would benefit from increased reach and improved line of sight provided through seat elevation in the final NCD. The benefits of seat elevation in the disability community are clear:

The proposed decision summary does not address the contribution of power seat elevation systems to contribute to a Group 3 power wheelchair users’ reach and line of sight. The proposed decision summary lacks adequate justification for the narrowly focused evidence question limiting the literature search to transfers. I strongly encourage a more comprehensive evidence search and broaden the evidence question consistent with previous national coverage analyses (NCA). The proposed decision for the benefit category decision established the medical nature of power seat elevation, so a broader question examining the full impact of these systems is warranted.

The proposed coverage criteria requires increased clarity of “weight-bearing transfers” and should include transfers other than weightbearing if the person cannot be transferred without seat elevate. Additionally, an occupational or physical therapist skilled in wheelchair seating and a complex rehab technology supplier (ATP) should be involved in the process to procure a power seat elevation system.

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I submitted this last year during a comment period. Here is is again. It's about ... time.

I am writing to request that the power wheelchair seat elevator be added to Medicare’s list of “medically necessary” items.

My wheelchair seat elevator is not a mere “convenience.” It is a substitute for [PHI Redacted]. It enables me to do all the necessary daily functions mentioned by hundreds of other commenters. And a few frivolous, unnecessary acts as well.

Before getting a power wheelchair with a seat lift, I experienced decades of difficulty standing up from any chair, manual wheelchair, bench, desk at school and work, bleachers, church pew, concert seat, toilet, inside a car, being on the ground.

My left hand pushed me up from those surfaces with very little help from my legs. For years, standing up was slow, uncomfortable, and embarrassing. The discomfort eventually turned into increasing pain as the bones in my hand, thumb, and wrist repeatedly collided with each other as I was trying to stand up. After many years, unrelenting pain lead to x-rays, medication, therapy, injections, hospitalization, and surgery. No doubt, those medically necessary interventions were costly.

After 45 years of being a part-time walking person and a part-time manual wheelchair user, I could no longer walk safely. I acquired a power wheelchair with a seat elevator. It felt like a miracle. Twenty five years later, I’m sitting in my 5th chair with that wonderful, medically necessary feature.

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Department of Health and Human Services
Centers for Medicare and Medicaid Services

Re: Request for public comments of Seat Elevation

3/16/2023

Dear Sir/Madam,

I appreciate the opportunity to comment on the proposed addition of coverage for seat elevation on power mobility devices.

Medicare is a leader in the purchasing of durable medical equipment, influencing coverage by state and private insurances. Your consideration and attention to innovation and advances in technology is critical as our nation turns its focus more toward value-based care.

As a practicing Occupational Therapist and Assistive Technology Professional with over 30 years of experience in seating and mobility. I recognize the benefits of seat elevation for transfers and much more.

In the 2019 literature update of the RESNA Position on the Application of Seat Elevation Devices for Power Wheelchair Users, RESNA identifies MULTIPLE areas where seat elevation is medically necessary, well beyond solely for transfers.

“It is RESNA’s position that power seat elevation devices are medically necessary as this technology enables certain individuals to:

• Facilitate reach biomechanics, safety and range

• Improve transfer biomechanics, safety and independence

• Enhance visual orientation and line-of-sight

• Support physiological health, safety and well-being.
  • Decrease hyper lordotic position of the neck.
  • Promote stable seated positioning.
  • Reduce symmetric tonic neck reflex (STNR) activity.
  • Improve Safety with performance/participation in ADLs.

• Promote communication, social engagement, self-esteem and integration.

• Improve wheelchair pedestrian safety.”

I appreciate that the CMS decision to support medical necessity for transfers may likely be correlated to falls with injury related to this specific task, and shoulder pain. Below I would like to highlight OTHER areas for consideration that support medical necessity beyond seat elevation for transfers.

1. Fall-related fractures in persons with spinal cord impairment: a descriptive analysis by Nelson in 2003 identifies that 11% of falls are sustained when reaching (i.e., not transfers). Seat elevation reduces the need for extended reach when completing activities of daily living. “Over 80% of patients with fall-related fractures were admitted for inpatient stays with a mean of 66 inpatient days per patient.”

Fall-related fractures in persons with spinal cord impairment: a descriptive analysis - PubMed (nih.gov)

2. Boninger’s research in 2003 identified 66% of subjects reported neck pain (NP) since becoming wheelchair users, with 60% of them seeking medical care for this pain.

“Sixty-six percent of subjects reported NP since becoming a wheelchair user and, 60% reported pain during the past month. Neither age nor length of time in a wheelchair was significantly different between those subjects who did and those subjects who did not report pain. Of those respondents who reported NP, 60% visited the doctor about the pain and 40% limited their daily activities due to the pain.”

Boninger ML, Cooper RA, Fitzgerald SG, et al. Investigating neck pain in wheelchair users. Am J Phys Med Rehabil. 2003;82(3):197–202.

Article PubMed Google Scholar

https://journals.lww.com/ajpmr/Abstract/2003/03000/Investigating_Neck_Pain_in_Wheelchair_Users.8.aspx

3. The United States Department of Transportation. National Highway, Traffic Safety Administration in 1997 published “Wheelchair Users Injuries and Deaths Associated with Motor Vehicle Related Incidents.” 26% of Wheelchair Users Injured or Killed were collisions between wheelchair and a motor vehicle. Of those, 14% were considered seriously injured. Of deaths that occurred 75% involved a collision between the wheelchair and a motor vehicle. When a collision between a wheelchair and a vehicle occurs, there is greater potential serious injury including death – more than any other cause, including improper securement, lift malfunction, transferring to/from vehicle or falling off ramp. Visibility to motor vehicles would be greatly improved with wider adoption of seat elevation on power wheelchairs.

https://rosap.ntl.bts.gov/view/dot/12760 United States Department of Transportation ROSAP >12760 1997-09-01 wheelchair User Injuries and Deaths Associated with Motor Vehicle Related Incidents

4. A case study by Nemire in 2010 in the Human Factors and Ergonomics Society Annual Meeting looked at Wheelchair Conspicuity at Night. In an analysis of NEISS data it conservatively estimated almost 900 collisions of motor vehicles and wheelchairs occur each year in the United States. Further stating “there are currently no federal regulations to enhance conspicuity of wheelchair as there are regulations to enhance the conspicuity of bicycles. Such regulations are needed.” Again, seat elevation would make wheelchair users more visible to drivers of motor vehicles.

Case Study: Wheelchair Conspicuity at Night
Kenneth NemireView all authors and affiliations
Volume 54, Issue 10
https://doi.org/10.1177/15419312100540100

5. Dr. John Kraemer assistant professor of health systems administration at Georgetown's School of Nursing & Health Studies and a scholar at the university's O'Neill Institute for National and Global Health Law analyzed police reports of road traffic collisions and news stories. He found that the mortality rate of pedestrians using wheelchairs is 36% higher than the overall population pedestrian mortality rate. "A high proportion of crashes occurred at locations without traffic controls or crosswalks," Kraemer said. "When there is poor pedestrian infrastructure or it's poorly adapted to people with mobility impairments, people who use wheelchairs often are forced to use the streets or are otherwise exposed to greater risk. It also may be telling that, in three-quarters of crashes, there was no evidence that the driver sought to avoid the crash."

“The potential role played by low conspicuity of wheelchair users is consistent with two findings: police attribution of 15% of crashes to the wheelchair rider not being sufficiently visible, and three-quarters of crashes involving no driver avoidance maneuver.

https://bmjopen.bmj.com/content/5/11/e008396

6. In 2021, Suk Won Choi published in Clinical and Experimental Emergency Medicine examining the Factors associated with injury severity among users of powered mobility devices.

Traffic accidents

“According to the Road Traffic Act, powered mobility device users are considered pedestrians and these devices are only allowed to be operated on sidewalks. However, the uneven, cracked, and sunken surfaces of some block-paved sidewalks, presence of trees lining the street and standing signboards, and certain road facilities may hinder the use of powered mobility devices, causing accidents.

Due to these factors, users operate powered mobility devices on the road instead of the sidewalk, and consequent collisions with cars and motorcycles lead to severe injuries. Seat elevation increases visibility of the wheelchair user and mitigates this serious issue.

Factors associated with injury severity among users of powered mobility devices

Suk Won Choi1, Jae-Hyug Woo2, Sung Youl Hyun3, Jae Ho Jang2, Woo Sung Choi2 Clin Exp Emerg Med 2021;8(2):103-110 https://doi.org/10.15441/ceem.20.078

7. Literature by Kirby in 2004 indicates that sustained neck extension and rotation increase neck discomfort for wheelchair users.

“Conclusions: Sustained extension and rotation of the neck, alone or in combination, increase the neck discomfort of wheelchair users. The MCP for most wheelchair users is straight ahead with the neck slightly flexed, about 11° and 27° more flexed, respectively, than when looking at an average-height sitting or standing person. These findings have implications for wheelchair design, the behavior of clinicians and wheelchair users, and the built environment.”

In summary, being constantly seated at waste-level has more than psychological effects, over time it’s painful and creates musculoskeletal problems which clinicians and Medicare then need to address (and pay for).

Kirby’sKirby RL, Fahie CL, Smith C, et al. Neck discomfort of wheelchair users: effect of neck position. Disabil Rehabil. 2004;26(1):9–15.

Article PubMed Google Scholar

https://www.tandfonline.com/doi/abs/10.1080/09638280310001621451

Above is just a small selection of the literature supporting the medical need/potential benefits of seat elevation beyond that for transfers alone. These include repetitive strain injury, fall risk, safety, all resulting in increase strain on the medical system and scarce insurance dollars. Medicare‘s intent when approving a wheelchair for a beneficiary is that it will be used within the home to go from the bedroom to the bathroom to the kitchen in reality it is used there and also in the community, with CMS holding the bill for the majority of the injuries that occur in the home and outside. CMS you consider these factors as it will provide better outcomes and lower cost by providing appropriate equipment for the actual values environment.

I enthusiastically support seat elevation coverage for transfer assistance. But also believe it is important for CMS to support seat elevation for those with neck pain and repetitive strain injury is, who are at risk for falls when reaching, accessing their vertical home environment, and for the safety of wheelchair users trying to access transportation in their communities to attend medical appointments.

Thank you for your consideration.

Dawn Hameline OTR/L, ATP

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The Disability Law Center, and Greater Boston Legal Services, write to support the Proposed National Coverage Determination for Power Seat Elevation Equipment on Power Wheelchairs dated February 15, 2023. This proposed determination is positive and a good step towards improving Medicare coverage of the modern complex rehabilitation equipment currently available to help beneficiaries with mobility limitations live more independent and safer lives at home.

The Proposed National Coverage Determination would revise NCD §280.3 to allow for coverage of power seat elevation equipment on Group 3 power wheelchairs when:

I am a Physical Therapist that has been evaluating for seat systems and wheelchairs for many years. I have had clients pay for this out of pocket since it is essential for their functional needs. I have worked with clients with the DX of MD and ALS for over 30 years and I am so excited to see you are looking at their needs for power elevation. Many of my clients can transfer but cannot get out of a regular height chair. This elevation will keep them independent in their ADLS and transfers. It will decrease the need for caregiver hours and decrease falls in the home.

I would like for you to consider that even though a client cannot stand to transfer they use the elevation all the time in everyday life- reaching into refrigerator cooking and even reaching for the elevator button. Being able to elevate keeps them able to be home independently in their home.

Thank you for the opportunity to submit comments

Please Medicare finalize this coverage of seat elevation systems to ensure that wheelchair users can access the care they need.

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As an Occupational Therapist practicing for 28 years, I want to thank CMS for recognizing power seat elevation systems as primarily medical in nature so my patients/clients have access to this enabling technology to meet their unique needs; Meeting the requirements to be deemed DMS and can be considered a covered benefit for my patients/clients to perform or participate in their MRADLs; and reasonable and necessary for my patients/clients who are Medicare beneficiaries, so they will have the same opportunities for coverage as my other patients/clients who are covered by health plans that already consider seat elevation as reasonable and necessary.

As an Occupational Therapist I am concerned CMS did not review and consider the submitted, peer reviewed research, subject matter expert consensus, or patient-centered outcomes data in support of the medical benefits derived for the application of seat elevation systems to preserve shoulder, upper spine, and neck integrity, or as a means for beneficiaries to perform or participate in their MRADLs. Many of the individuals who use complex rehab equipment need the seat elevation system to allow them to participate all day in their MRADL’s. In addition to their MRADL’s, many of these folks would fatigue with the amount of reach activities they need to participate in throughout the day without seat elevation, this fatigue can and at times does reduce the amount of hours that they can independently drive their power wheelchair. By allowing an individual to elevate to enhance/provide ergonomically correct reaching the person is preserving their ability to participate in all MRADL’s over a longer period of time during the day.

I encourage CMS to include coverage for Medicare beneficiaries who need a seat elevation system to reach the locations, surfaces and objects in their home required to support their health and safety, and to perform or participate in their MRADLs.

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Association of Assistive Technology Act Programs
655 15th St. NW, Washington DC 20005

March 17, 2023

The Honorable Chiquita Brooks-LaSure
Administrator
Centers for Medicare and Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

Re: CAG-00461N: Seat Elevation Systems as an Accessory to Power Wheelchairs

Dear Administrator Brooks-LaSure:

On behalf of the Association of Assistive Technology Act Programs (ATAP), we are pleased to submit comments and recommendations to the Centers on Medicare and Medicaid Services (CMS) regarding National Coverage Determination (NCD) regarding Seat Elevation Systems as an Accessory to Power Wheelchairs.

ATAP represents State and Territory Assistive Technology Programs formula funded under Section 4 of the Assistive Technology (AT) Act. State and Territory AT Act programs operate in all 50 states, the District of Columbia, Puerto Rico and four territories and are available for persons with all types of disabilities, all ages, in all environments (education, employment, community living and information technology). AT Act Programs are able to best match the proper assistive technology (AT) with individuals’ needs, provide a device demonstration, loan a device, and provide training and support for the use of the device. Assistive technology and/or adaptive equipment can facilitate, support and improve functionality so every individual with disability can obtain an education, gain and main employment and live independently in their community.

ATAP supports CMS’ proposal to recognize seat elevation systems as primarily medical in nature and reasonable and necessary for beneficiaries who qualify for this benefit. Medicare coverage of seat elevation as a durable medical equipment (DME) benefit makes sense as CMS seeks to meet the needs of Medicare beneficiaries with mobility impairments with respect to access to assistive devices and technologies. We offer the recommendations below to help CMS ensure that all beneficiaries who need access to power seat elevation systems will receive coverage for them.

Recommendation: Need for an Additional NCD on Standing Systems in CRT Power Wheelchairs: While ATAP supports the current NDC, it is essential that CMS also open an NCD request for coverage of standing systems in CRT power wheelchairs. Given the critical function of standing systems, ATAP urges CMS to open an NCD that would highly complement seat elevation coverage and address another critical need of beneficiaries with mobility disabilities.

Recommendations for current NCD:

1. Finalize the proposed Benefit Category Determination holding that power seat elevation systems are primarily medical in nature and are considered durable medical equipment under the Medicare benefit; and finalize the proposed decision that seat elevation is reasonable and necessary for Medicare beneficiaries with mobility impairments who need seat elevation to perform weight-bearing transfers and aid in the performance of MRADLs, with or without assistance from another person. CMS’s previous decision in 2005 deemed these critical features “convenience items” and referred to them in subsequent years as “luxury” items. ATAP appreciates that CMS has finally recognized the medical nature of seat elevation systems in CRT power wheelchairs. We hope this change in perspective signals a sea change in the way CMS meets the needs of Medicare beneficiaries with mobility impairments with respect to access to assistive devices and technologies.

2. Include coverage of seat elevation for Medicare beneficiaries who use Group 2 CRT power wheelchairs in the final NCD and urges consideration of use of a functional test that assesses each patient based on their medical and functional needs. ATAP believes the benefit category determination analysis of the proposed NCD decision and the evidence base is just as applicable to Group 2 power wheelchair users as it is to Group 3 power wheelchair users. There is no principled reason to grant seat elevation coverage to one group of beneficiaries and not the other. CMS’s question as to coverage of seat elevation for Group 2 CRT users is highly device-focused rather than patient-centric. Medicare’s current LCD for Mobility Assistive Equipment (MAE) restricts coverage of Group 3 power wheelchairs to beneficiaries with a mobility limitation that is due to a neurological condition, myopathy, or congenital skeletal deformity. Beneficiaries who do not have these specific diagnoses will not have access to seat elevation unless CMS includes seat elevation coverage for users of Group 2 CRT power wheelchairs in its final NCD. Rather than employing a diagnostic approach, CMS should consider use of a functional test that assesses each patient based on their medical and functional needs, not based on the origin or diagnosis that caused their mobility impairment.

3. Provide important clarifications to the proposed NCD, including further detail regarding “weight-bearing transfers,” beneficiaries using patient transfer devices, and the specific criteria for specialty evaluations. CMS proposes to require that individuals seeking coverage for seat elevation must undergo a “specialty evaluation” by a practitioner with specific training and experience in rehabilitation wheelchair evaluations (the licensed/certified medical professional or LCMP). This is already standard practice for the provision of power wheelchair features on CRT power wheelchairs to wheelchair users, and we support this requirement. CMS already prescribes specific requirements for evaluations to provide beneficiaries with power wheelchair bases and power seating functions such as the tilt and recline feature. We encourage the agency to clarify that the same standards should apply for evaluations of a beneficiary’s need for power seat elevation. This should include the required involvement of an assistive technology professional (ATP) employed by the wheelchair supplier who can provide direct, in-person training and assistance for the beneficiary.

CMS should also institute the condition that the LCMP conducting the evaluation does not have a financial relationship with the seat elevation supplier. In our experience, the clinician and supplier work together through the evaluation and assessment process to consider the beneficiary’s medical needs, clinical conditions, and other factors that drive the specific technology recommendation. This may include, but is not limited to, the activities of daily living in the home environment, functional needs and capabilities, and the technology solutions designed to ameliorate the mobility challenges. the team will identify the least costly, but medically appropriate technology and consider contraindications that would prevent the beneficiary from using certain technologies. This approach provides protection for the beneficiary and Medicare’s expenditures as the clinical and technology decision-making process that occurs is documented in the beneficiary’s medical record.

ATAP appreciates the opportunity to comment. Please let me know if we can provide any additional information.

Sincerely,

Audrey Busch
ATAP
Executive Director

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March 17, 2023

Ms. Chiquita Brooks-LaSure
Administrator
Centers for Medicare & Medicaid Services
200 Independence Ave., S.W.
Washington, D.C. 20201

Re: Comments on CMS National Coverage Analysis for Seat Elevation Systems as an Accessory to Power Wheelchairs (Group 3) Introduction

Administrator Brooks-LaSure:

Permobil is the leading manufacturer of complex rehab technology (CRT) equipment, including Group 3 power wheelchairs. We pride ourselves in providing safe and reliable mobility and seating solutions that allow people with complex medical needs to enjoy their best life. Permobil appreciates the opportunity to submit comments on the Centers for Medicare and Medicaid Services’ (CMS’) Proposed Decision Memo on Seat Elevation Systems as an Accessory to CRT Power Wheelchairs (Group 3). Seat elevation systems allow for wheelchair-bound patients to safely and independently perform activities of daily living (ADLs), allowing them to live a more fulfilling and productive life. Being able to safely perform or participate in activities of daily living minimizes the potential for serious injuries, which reduces costly emergency room visits and/or hospitalizations.

CMS is proposing that power seat elevation equipment on CRT Group 3 power wheelchairs falls within the benefit category for durable medical equipment (DME) and that the evidence is sufficient to determine that power seat elevation equipment is reasonable and necessary for individuals using CRT power wheelchairs when the following conditions are met:

The Academy of Neurologic Physical Therapy (ANPT), a component of the American Physical Therapy Association (APTA) is requesting that Medicare provide coverage for seat elevation systems on power wheelchairs for people with mobility-related disabilities. Many individuals with a wide variety of neurologic diagnoses require the features of a complex rehab technology (CRT) power wheelchair and power seating system to meet their clinical and functional needs and goals. The ANPT supports coverage for power seat elevation systems for beneficiaries with mobility impairments resulting from neurologic conditions to help them achieve their best health, function, participation outcomes.

Further, ANPT would also recommend Medicare expand coverage of power seat elevation to include Group 3 power wheelchair users. Many individuals who do not have a diagnosis to qualify them for a Group 3 power wheelchair, still have needs for features only available on a Group 3 power wheelchair. Individuals who have severe Rheumatoid Arthritis and joint contractures and individuals with multiple co-morbidities plus lower extremity lymphedema are good examples of individual who clinically and functionally require a power wheelchair with multiple power seat functions; yet, there is no Group 2 power wheelchair on the market that meets their needs. ANPTs suggest Medicare consider a functional qualification for a Group 3 multiple power seat function power wheelchair for these individuals based on the evaluation of a physical or occupational therapist. In addition, for the population with lower extremity amputations, a power seat elevator is often critical for functional transfers, reaching within the home for mobility related activities of daily living (MRADLs), and for community participation and safety.

By providing beneficiaries with these power seat functions we will not only improve their quality of life; but also, promote their ability to perform independent and safe transfers; increase functional reach; reduce falls; mitigate risk for upper extremity and cervical pain; promote function and independence with MRADLs; increase community participation, communication, and positive self-image for power wheelchair users.

Improve safety with transfers, improve functional reach, reduce risk of falls

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Re: CAG-00461N – Proposed Coverage Decision Memo: Seat Elevation Systems as an Accessory to Power Wheelchairs (Group 3)

The following comments are submitted on behalf of Quantum Rehab in response to the CMS Proposed Decision Memo: Seat Elevation Systems as an Accessory to Power Wheelchairs (Group 3).

Quantum Rehab is a world leader in the design, development, and manufacture of mobility products – including complex rehab power wheelchairs, seating and position systems, and other components designed to best address the individual medical needs of consumers with mobility impairments as diagnosed by their physician and clinical team.

We strongly support Medicare’s Proposed coverage of seat elevation systems. Power seat elevation is an essential component of a complex rehab power wheelchair that enables individuals to perform or participate in their mobility-related activities of daily living (MRADLs) in the home. Power seat elevation systems have been available for years and are covered by most other payers, including state Medicaid programs, commercial health plans, and the Veteran’s Administration.

Quantum Rehab is a company focused on bringing the most innovative products to the market. We regularly host consumer focus groups to receive input from people with disabilities and mobility impairments on the daily challenges they incur and then put our heads together to design and develop a way to address them. One result of this process was the development of our iLevel power seat elevation system 8 years ago. Consumers were looking for a safe seat elevation system that would allow them to move about while elevated to access the vertical environment and participate in their MRADLs, a standard for Medicare coverage of mobility assistive equipment (MAE) more fully.

While a power wheelchair provides the user with 360° of movement in a two-dimensional plane we live in a three-dimensional world. As such, access to the vertical environment is often precluded for individuals with a permanent disability who meet the coverage criteria for a power wheelchair. This negatively impacts their ability to perform or participate in their MRADLs safely and in a timely manner often resulting in the unnecessary expense of personal care assistance (PCA) or a preventable adverse occurrence.

The need for a power seat elevation system is not only necessary to improve transfers, but it also improves beneficiary access to the vertical environment for reach and line of sight requirements to safely and effectively engage in one’s MRADLs. This is supported by the medical evidence, subject matter expert consensus, patient-centered outcomes data, and is recognized by national disability and medical organizations.

Summary of Specific Comments on Proposed Coverage Decision:

Quantum Rehab urges CMS to finalize the National Coverage Determination as follows:

1. Finalize the proposed Benefit Category Determination (BCD) that power seat elevation systems are primarily medical in nature and are considered durable medical equipment under the Medicare benefit.
2. Finalize the proposed coverage determination holding that these systems are reasonable and necessary for Medicare beneficiaries who use Group 3 and above CRT power wheelchairs in order to transfer for the purpose of performing or participating in MRADLs;
3. Include coverage for Medicare beneficiaries who need seat elevation to improve their reach and line of sight to support shoulder, upper spine, and neck integrity while performing or participating in MRADLs;
4. Include coverage of seat elevation for Medicare beneficiaries who use Group 2 CRT power wheelchairs in the final NCD; and
5. Provide clarifications to the proposed NCD, including further detail regarding “weight-bearing transfers,” for beneficiaries using patient transfer devices, and
6. Follow the requirements for the provision of other power seat functions (power tilt and/or power recline) regarding the specific criteria for specialty evaluations, and include a requirement for the seat elevation system to be provided by a supplier that employs a RESNA certified Assistive Technology Professional (ATP) who specializes in wheelchairs and has direct, in-person involvement in the wheelchair selection for the beneficiary.

Medicare Coverage for Power Seat Elevation Systems Should Not Limited to Non-Level Transfers

Quantum Rehab supports CMS’ proposed benefit category decision that recognizes power seat elevation systems as primarily medical in nature. There are, however, several issues with CMS’ proposed decision summary. We strongly support the ITEM Coalition’s Comments, along with NCARTs, CTF’s and others, responding to CMS’ Proposed Decision as they provide significant clinical support and detailed rationales for CMS to modify and improve its coverage decision for power seat elevation systems.

Quantum Rehab recommends CMS modify and improve its final coverage decision as follows:

a. Seat elevation systems serve a medical purpose for all transfers, not just un-level transfers.

b. In addition to transfers, seat elevation systems serve the medical purpose of reach in a way that minimizes the risk for pain and injuries while completing MRADLs. We refer CMS to the peer review research related to the application for power seat elevation system for reach that were submitted with the ITEM Coalition’s original September 2020 request to CMS.

c. The evidence base on reach and line of sight supports the medical nature of power seat elevation for these purposes. The recommendation to expand the coverage criteria to include reach is consistent with criteria under eleven state Medicaid programs (CA, CO, ID, IA, MN, NY, NC, SD, TN, TX, & WI).

1. Any transfer in which the beneficiary bears weight on their upper and/or lower extremities during the execution of the transfer;
2. May be performed with or without the assistance of a caregiver;
3. May be performed with or without the use of other mobility assistive equipment such as, but not limited to canes, crutches, walkers, etc.; and,
4. May be performed with or without the use of a transfer assist device such as, but not limited to a sliding/transfer board, transfer assist handles, trapeze, transfer/pivot disk, sit-to-stand device.

Coverage when Used with a Group 2 Power Wheelchair

CMS requested comments on whether power seat elevation equipment on Group 2 power wheelchairs primarily and customarily serves a medical purpose and thus also falls within the benefit category. It does and we strongly recommend that CMS include power seat elevation on Group 2 power wheelchairs for those with certain clinical conditions.

Some Medicare beneficiaries who meet the criteria for a power wheelchair, but do not meet the criteria for coverage of a Group 3 power wheelchair (e.g., lower extremity acquired Absence of Limb(s), Lupus, Inclusion Body Myositis, Myasthenia Gravis, (Poly)Neuropathy, Rheumatoid Arthritis, Scleroderma, and/or an advanced stage of one or more chronic medical condition) may benefit from having a Group 2 power wheelchair with a seat elevation system to transfer. For Medicare beneficiaries who are deemed a high fall risk or have fallen while in a standing position, with attempts to stand, or during a transfer the seat elevation system improves transfer biomechanics, safety and independence, and will reduce the number of fatal and non-fatal falls for individuals over 65.

Power Seat Elevation System as a Power Seat Function

Quantum Rehab strongly recommends CMS determine that a power seat elevation system is a power seat function, like power tilt and power recline, and require the same level of beneficiary protections as the other two power seat functions. Specifically, we recommend the coverage criteria for power seat elevation be revised to require:

We strongly urge CMS to deem a PWC with either power tilt only, power recline only, or power seat elevation only as a single power option base and that any combination of power tilt and recline, power tilt and seat elevation, power recline and seat elevation, or power tilt, recline and seat elevation be deemed a multiple power option base. This is because the engagement of any of these three power seat functions alone or in combination change the center of gravity of the unit when they are engaged, affecting the dynamic stability of the power wheelchair base. It is, therefore, imperative that power wheelchairs with a power seat elevation system be required to pass all ANSI/RESNA testing specifications for dynamic stability where the dealer adjustments are set to the least stable configuration in which the PMD drives in full speed. Further, if the PMD’s speed is reduced (creep mode) after the power seat elevation system is engaged it must pass the additional dynamic stability driving tests (forward stability, rearward stability, and lateral stability) on a ramp in the least stable configuration in which the chair drives at the reduced speed.

Any power wheelchair with a seat elevation of at least 6” must be tested as a single or multiple power option base, with the seat elevation system included, by an independent test lab for PDAC code verification.

Conclusion

We strongly support Medicare’s Proposed coverage of seat elevation systems and thank you for recognizing the extensive clinical evidence supporting coverage of this technology. We encourage Medicare to quickly finalize a coverage decision that ensures all beneficiaries who can benefit from seat elevation technology have access to it.

If you have any questions or would like additional information, I can be contacted at sjohnson@pridemobility.com or 1-800-800-8586 x1481.

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Thank you for this proposal. As a family member of a brother, 2 nephews, and 1 great-nephew who have used wheelchairs due to [PHI Redacted], I support this Benefit Category Determination and coverage decision.

I would also like to request the following:
1) Extension of the coverage proposal to improve reach & line of sight to support shoulder, upper spine, and neck integrity; and
2) Access to seat elevation for users of Group 2 power wheelchairs.

Quality of life, safety, and independence will be greatly enhanced through this proposed coverage decision. I appreciate the support from CMS regarding these critical benefits.

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Occupational Therapy Student

I appreciate the opportunity to comment on opening the national coverage determination (NCD) for Mobility Assistive Equipment (MAE) to consider coverage for power seat elevation and power standing systems under Medicare. My name is Sarah DiCioccio, and I am an Occupational Therapy Student (OTS) at Saint Joseph’s University. Have you ever had to gaze down at someone you were speaking with while they were seated in a wheelchair? If the wheelchair that person was using had the seat elevation mechanism, they could raise the seat to the other person's eye level and have a proper conversation without feeling different because they are in the wheelchair and not standing. In occupational therapy, we help our clients engage in all kinds of occupations such as activities of daily living (ADLs) including showering, toileting, dressing, eating, feeding, functional mobility, sexual activity, and personal hygiene and grooming. Instrumental activities of daily living (IADLs) including care of pets, child rearing, driving and community mobility, financial management, safety, shopping, religious and spiritual expression, and meal preparation. We also help with health management, rest and sleep, education, work, play, leisure, and social participation. If the client has a power standing system and a power seat elevation, each of the above occupations could be easier to engage in.

I fully believe that Medicare should extend the coverage of seat elevation and standing systems in power wheelchairs for Medicare beneficiaries with mobility impairments. Here’s why, there are numerous health benefits of these systems. In a recent article from Masselink et al., (2021), there is evidence gathered that standing has been shown to improve comorbidities and secondary health issues that are linked to the disease or condition. Standing can help strengthen upper and lower extremity range of motion, increase muscle tone or spasticity, management of urinary and digestive systems, pressure sores, and ADLs such as toileting, dressing, feeding, and bathing (Masselink et al., 2021).

The functional benefits for power seat elevation are that it helps with safe and independent transfers such as transferring from the power wheelchair to the bed. The power wheelchair can rise to the correct height of the bed thus making it easier for the client to transfer onto the bed. The functional benefits for power standing systems are that it enables the client to have access to things that are higher than waist level such as upper cabinets in the kitchen or bathroom. The client would not be able to reach tall objects, such as cabinets, if they were in a standard wheelchair without a power standing device.

Thank you once more for giving me the opportunity to share my thoughts on the need of Medicare covering power standing systems and power seat elevation for those with medical disabilities. I would encourage Medicare to speedily approve coverage of power standing systems and power seat elevation to ensure that wheelchair users can have the best life possible.

Sarah DiCioccio, OTS
3/17/23

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I want to thank CMS for recognizing power seat elevation systems as: Primarily medical in nature, meeting the requirements to be deemed DME and reasonable and necessary for Medicare beneficiaries. I strongly support Medicare coverage for power seat elevation systems: To provide access to this enabling technology for Medicare beneficiaries who qualify for this benefit.

The individual performs weight bearing transfers to/from the power wheelchair while in the home, using either their upper extremities during a non-level (uneven) sitting transfer and/or their lower extremities during a sit to stand transfer. Transfers may be accomplished with or without caregiver assistance and/or the use of assistive equipment (e.g., sliding board, cane, crutch, walker).

RE: Transfers
Transferring from a wheelchair to other surfaces such as a bed, toilet, or other surface is a necessary part of the daily routine; Transferring is a means to accomplish MRADLs, and therefore it is considered a medical necessity; and, seat-elevating devices improve transfer biomechanics, safety, and independence.

RE: Weight Bearing Transfers

I am concerned whether the agency intended to prohibit coverage of seat elevation systems for wheelchair users who cannot assist with the transfer themselves and rely significantly on caregiver assistance and/or the use of assistive equipment. Often with a seat elevation system and transfer training the person can rely less on a caregiver and/or assistive equipment to transfer.

I am concerned that the reference to weight bearing transfers may exclude certain beneficiaries from accessing a seat elevation system, especially if they cannot transfer themselves, and request CMS consider that these beneficiaries still derive medical benefit from a seat elevation system to perform MRADLs in the home once the transfer is complete.

Mechanical Lift Transfers and Reach

I encourage CMS to consider coverage of a seat elevation system for people who use a patient lift/transfer system to be safely transferred to their PWC and have the capability of using their upper extremities to perform or participate in their MRADLs from a seated position using the seat elevation system.

RE: Reach

I encourage CMS to include coverage for Medicare beneficiaries who need a seat elevation system to reach the locations, surfaces and objects in their home required to support their health, safety, and perform or participate in their MRADLs.

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Seat elevation systems, for many power wheelchair users — including some with intellectual and developmental disabilities — are essential to their ability to negotiate a wide range of critical needs, including moving from wheelchair to other chairs, entering and exiting various spaces and conveyances,and being able to see, hear and participate in meetings and events of all kinds.

Thus, elevation systems afford such individuals not only increased access in a general sense, but also, in tangible ways, afford them increased safety, health, situational awareness (for example, with regard to emergencies) and increased ability to be recognized by, and to interact with, others. This is crucial for well-being in a myriad of ways.

I have seen the big difference elevation systems make in the lives of physically, intellectually and developmentally disabled individuals.

It is crucial that Medicare coverage be provided for these systems.

Thank you for your attention to my concerns as a family member of and advocate for people with intellectual and developmental disabilities.

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[PHI Redacted] I have gotten weaker over the years and received a Quantum Edge 2.O power wheelchair 7 years ago, I paid $1,500. for the seat elevation cost at that time. Having now used my chair for 7 years it has been very helpful to have the seat elevation feature. I have used seat elevation to raise my seat to reach items that I could not at normal level. This has benefited me by allowing me to use my arm and keep more active and lessen muscle loss. For example, seat elevation helps me to reach light switches and thermostat. Seat elevation helps me adjust to lower to floor to rest my feet. I'm not able to stand or walk so any amount of comfort helps. Seat elevation is also important when trying to get into either a TARC 3 vehicle with a side ramp or a car that has a side ramp. I'm 6 foot 3 so I use seat elevation to adjust chair to be able to get into a vehicle because of my height. Seat elevation helps me raise chair to talk with people better when needed. I have a lot of fatigue so it's harder for me to talk so getting closer to people standing helps. To tilt my chair and relieve pressure on my bottom I use seat elevation to move chair closer to floor so the tilt feature will work. Being able to use seat elevation helps me mentally just being able to move up or down more.

I believe Medicare should finalize its proposal to cover seat elevation systems in power wheelchairs for Medicare beneficiaries with mobility disabilities.

I'm thankful and blessed to have seat elevation technology. I believe anyone who has a medical need or the ability to use seat elevation should have this technology covered. Just this past Wednesday I went to Frazier Hospital Rehab and started the process to replace my power chair with a new power chair and asked for seat elevation as it has been very helpful. My chair needs to be replaced and not paying the $1,500 cost would be a big relief financially for our family.

Please approve Medicare coverage for seat elevation and standing systems TODAY!

Thank you for the opportunity to submit comments.

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Hello,
Thank you so much for considering this addition to coverage for patients. As a clinician I have worked as a physical therapist with patients following catastrophic injury or neurological illnesses. Seat elevation is so key to our patient's independence and has been limited to date to those with the socioeconomic ability to fund this feature. This gap in coverage has contributed to health care disparities leading certain individuals to reach their maximal functional abiliites and others to continue to be dependent on others. Unfortunately, this has impacted the long term housing options that many of my patients have been able to consider.

Luckily, [PHI Redacted] was blessed to have the resources to obtain the seat elevation feature on his power wheelchair. This feature allowed him to perform lateral transfers independently, access upper cabinets in his bathroom and kitchen, look through the peep hole of the front door, and perform basic cooking tasks. As the primary caregiver for [PHI Redacted], this feature allowed them to remain in their home and living independently without caregivers in place. Seat elevation gives such independence in the home and this is only expanded once the patinet leaves the home. Please consider moving forward with adopting this new policy and consider expanding it to those who utilize only mechanical lift transfers. The benefits of seat elevation are so much more than transfers.

Thank you.

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Thank you for responding to the needs for provision of power Seat Elevation for use with complex power wheelchairs. I strongly support Medicare coverage for power seat elevation systems as essential components for many consumers using complex power wheelchairs. Not only will this component be important for safe transfers in/out of the power chair, but will facilitate independence for many, in the areas of grooming, cooking, retrieving items from high surfaces, open opportunities for employment access, as well as traversing city cross-walks (being seen/visibility above parked cars at intersections)

There are many situations requiring the need for power seat elevation. The provisional requirement of weight bearing transfers does not provide clarity and may preclude coverage for many consumers who are dependent on it...such as the young man with Duchennes Muscular Dystrophy who's mother is his primary caregiver. Mother is 5' tall and must lift him from wheelchair to bed, shower chair, etc. The use of power seat elevation ensures safety for them both as they are able to elevate or lower the seat relative to the surface being transferred to/from. Or the person with Cerebral palsy who has a caregiver in the home only in the morning and late evening. Use of power seat elevation allows them to independently navigate all surfaces of their environment in able to remain independent while at home alone.

While considering the provisional requirements for power seat elevation, please carefully consider the information above, as well as the vast public commentary regarding this. Once again, thank you very much for moving forward with provision of this very essential component!

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Re: NCA - Seat Elevation Systems as an Accessory to Power wheelchairs (Group 3) (CAG-00461N) - Proposed Decision Memo
March 17, 2023
I would like to convey my excitement and pleasure that CMS has recognized the medical nature of power seat elevation systems and has proposed a benefit category decision that will allow access to these important systems for many power wheelchair users.

However, as a person who is intimately aware of both the evidence base on power seat elevation systems and the policies and national coverage analyses for mobility assistive equipment and the iBOT, I am primarily concerned that a federal agency with the strategic plan for “advancing health equity, expanding coverage, and improving health outcomes” would utilize the poorly founded justification that the 2006 iBOT evidence is sufficient to rule out power seat elevation systems for reach (as further explained in the Clinician Task Force public comment) in order to examine a very narrow evidence-based question focused on transfers only. The only visible reason for this decision is to limit coverage on this necessary system that serves to reverse the impact of being positioned in a fixed manner at a low height – thereby, without power seat elevation, actually preventing some beneficiaries from accomplishing activities of daily living, known to CMS as MRADLs.

CMS documents including the Medicare Program Integrity Manual 13.5.3 (rev. 863, 2019), 13.7.1 (rev. 608, 2015), and Federal Register (CMS–3284–N, 2013) clearly describe that peer-reviewed studies published between 2006 and 2023 are just as relevant to this issue as published evidence before 2006, by stating that evidence published in peer-reviewed medical journals, that are evidence-based consensus statements, and/or clinical guidelines should be considered in when making policy decisions. CMS lacked to consider a significant portion of the evidence base by omitting the past 17 years of evidence (a key point that the iBOT decision stated) and utilize evidence from a search whose terms did not even include the power system examined today.

I support the Clinician Task Force, ITEM Coalition, RESNA’s public comments made on this proposed benefit category decision. I avidly request that CMS carefully consider the comments made by power wheelchair users themselves – these comments alone, from this public comment period and the previous public comment period, should be considered as significant evidence that power seat elevation systems are necessary for power wheelchair users in the performance and participation of their activities of daily living.

I request that CMS establish the benefit coverage decision in the NCD for Mobility Assistive Equipment and utilize the LCD for specific coverage conditions, as would be consistent with other similar power functions, tilt and recline.

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Dear Administrator Brooks-LaSure:

Numotion is pleased to submit these comments on the Centers for Medicare and Medicaid Services’ (CMS) proposed National Coverage Decision (NCD) for seat elevation systems in Complex Rehabilitation Technology (CRT) power wheelchairs. We applaud CMS for proposing to recognize seat elevation systems as primarily medical in nature and reasonable and necessary for beneficiaries who qualify. We offer these comments in response to the proposed NCD to urge CMS to clarify certain language in the proposed NCD and to consider revising language to ensure that all Medicare beneficiaries who need access to power seat elevation systems will benefit from coverage for them.

Specifically, Numotion urges the agency to:

1. Finalize the proposed Benefit Category Determination that power seat elevation systems are primarily medical in nature and are considered durable medical equipment under the Medicare benefit and finalize the proposed coverage determination that these systems are reasonable and necessary for Medicare beneficiaries who use Group 3 CRT power wheelchairs in order to perform transfers for the purpose of performing or participating in mobility related activities of daily living (MRADLs);
2. Include coverage for Medicare beneficiaries who need seat elevation to improve their reach and line of sight to support shoulder, upper spine, and neck integrity while performing or participating in MRADLs;
3. Include coverage of seat elevation for Medicare beneficiaries who use Group 2 CRT power wheelchairs in the final NCD; and
4. Provide clarifications to the proposed NCD regarding “weight-bearing transfers;”

1. Numotion Supports the Proposed BCD and Coverage Proposal

Numotion supports CMS’s decision to consider seat elevation as primarily medical in nature and, therefore, a covered durable medical equipment benefit under the Medicare program. These critical features are neither “convenience items” nor “luxury” items, as they have been referred to in the past. CMS has appropriately acknowledged, based on strong support in the literature, the medical nature of seat elevation systems in CRT power wheelchairs.

Similarly, we support the proposed decision that seat elevation is reasonable and necessary for Medicare beneficiaries with mobility impairments who need seat elevation to perform weight-bearing transfers and aid in the performance of MRADLs, with or without assistance from another person. The evidence cited in NCD Request for Reconsideration establishes that seat elevation has a material impact on the ability to perform MRADLs safely and efficiently while reducing the incidence of secondary injury.

2. Coverage to include improvement of reach and line of sight

In fact, the evidence goes further and supports seat elevation for the purposes of improving reach and line of sight for the purpose of performing MRADLs while limiting secondary injury. The need for and benefits of a power seat elevation system to improves transfers, improves beneficiary access to the vertical environment for reach and line of sight requirements to safely and effectively perform or participate in MRADLs, is supported in the evidence base, by subject matter expert consensus, patient-centered outcomes data, and is recognized by national disability and medical professional organizations. It is also supported by third-party payers such as the Veterans Administration, state Medicaid programs, and private payers that currently provide coverage of seat elevation to individuals with mobility impairments. Numotion encourages CMS to base the scope of its final decision on the strength of the evidence and acknowledge that seat elevation is reasonable and necessary for Medicare beneficiaries with mobility impairments who need seat elevation to improve reach and line of site to perform MRADLs.

3. Coverage of power seat elevation for Medicare beneficiaries in need of Group 2 CRT power wheelchairs

CMS specifically solicited comments in response to the proposed NCD about whether coverage for seat elevation should extend to Medicare beneficiaries in need of Group 2 CRT power wheelchairs. Again, Numotion encourages the agency to base its final determination on this topic on the weight of the literature and the evidence and include coverage of seat elevation for Medicare beneficiaries who use Group 2 CRT power wheelchairs in the final NCD.

4. Clarification on the Proposed NCD

Numotion encourages CMS to clarify the meaning of “weight bearing transfers” or eliminate the language altogether. The proposed decision memo states that power seat elevation can be found to be reasonable and necessary for beneficiaries who perform “weight bearing transfers” to and from their power wheelchair within the home. The coverage criteria goes on to say that this can include the use of upper extremities for non-level sitting transfers and/or the use of lower extremities during a sit-to-stand transfer, and can be supported with or without caregiver assistance. However, the decision memo does not further elaborate on the intended meaning and any limitations included in the term “weight bearing transfers.”

We request that CMS clarify that this term is not intended to exclude certain beneficiaries from accessing seat elevation technology, particularly those that perform dependent transfers. As currently worded, beneficiaries are left to wonder whether the agency intended to prohibit coverage of seat elevation for those wheelchair users who cannot assist with transfers themselves and thus rely on significant caregiver assistance. These beneficiaries could certainly still derive a medical benefit from power seat elevation to perform MRADLs, the standard of coverage for mobility devices under the Medicare program. They could also derive a medical benefit from the ability to rise to a higher plane to provide level or downward transfers which could prolong the ability of caregivers to help beneficiaries facilitate safe transfers without injury.

We encourage CMS to clarify its intended interpretation of this coverage criterion in the final decision memo to include all individuals who would benefit from seat elevation systems for the performance of transfers.

5. Support from Congress and Other Stakeholders

The issue of seat elevation coverage has garnered significant support from lawmakers. More than 130 members of both houses of Congress, from both sides of the aisle, have urged the agency to cover these important power wheelchair functions.

Similarly, the National Council on Disability, supports these efforts. Medicare coverage of seat elevation and standing systems in power wheelchairs remains an important component of the Council’s Health Equity Framework for People with Disabilities, originally released in February 2022. The Council also hosted a stakeholder Roundtable discussion on coverage of these systems in August 2022. The Roundtable emphasized the evidentiary foundation for Medicare coverage of these important benefits for persons with mobility impairments with every speaker strongly supporting Medicare coverage of both seat elevation and standing systems.

Other stakeholders of all kinds are also overwhelmingly in support of coverage of seat elevation systems. During the initial comment period, CMS received over 3,600 separate and unique comments from Medicare beneficiaries with mobility impairments, rehabilitation therapists, physicians who treat this patient population, rehabilitation hospitals, seating clinics, researchers, manufacturers and suppliers, and the general public. The comments were unanimous in their support of Medicare coverage for seat elevation systems.

We applaud CMS for recognizing the significant clinical evidence and overwhelming public support for covering seat elevation in CRT power wheelchairs and encourage the agency to quickly finalize a coverage decision that ensures all beneficiaries who can benefit from seat elevation are able to access this technology under the Medicare program.

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My name is Ashley Sequeira. [PHI Redacted] I am a full-time power wheelchair user who is dependent on others for all transfers and repositioning. However, my power wheelchair and its seat functions, including a seat elevator, are the primary reason I am able to live independently and work full-time. It is important to note I did not always have a seat elevator, and the detriment it caused to my health and safety.

[PHI Redacted] At the time, I did not have a seat elevator nor a bathroom that worked with a hoyer lift (at home, college, or anywhere else), and my doctors believed the constant tension on the rods from bear-hug transfers at my stationary, low wheelchair height weakened and eventually broke the rods. [PHI Redacted] The unfortunate part of this is it could have been prevented had I been provided a seat elevator.

It's vital to note that seat elevators don’t only provide health benefits, but also massive functional and safety benefits in the daily lives of those who use them. I, as well as many others who use power wheelchairs, don’t have caregiver coverage 24/7. We rely on public transportation and navigating the outside world via our power wheelchairs. Prior to having a seat elevator, I frequently could not reach crosswalk buttons. This meant I had to cross the road, sometimes busy city intersections with 3 lanes each, while cars were still driving. Vehicles frequently had to slam on their breaks to avoid hitting me. In my old college, I relied on students or staff to press a certain elevator button for me due to its height. If I couldn’t find someone in time, I was late to class. There were various times I got into a subway elevator, only to become stuck due to the height of the buttons.

CMS supporting seat elevators helps prevent the hospitalizations, or even worse, institutionalization of those who could otherwise be healthy and independent had they been provided with seat elevators. They are quite literally lifelines for us. Thank you for taking the time to consider my experience, which is merely one of many.

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On behalf of the American Medical Rehabilitation Providers Association (AMRPA), we appreciate the opportunity to offer our strong support for the Centers for Medicare & Medicaid Services’ (CMS) proposed national coverage determination (NCD) related to seat elevation systems as an accessory to power wheelchairs. We specifically applaud the NCD’s finding that seat elevation systems in Group 3 power wheelchairs are primarily medical in nature and therefore fall within the Durable Medical Equipment category. Our members provide critical rehabilitation services to persons with disabilities, including beneficiaries who use Group 3 chairs, and we believe this policy will immediately and dramatically increase access to this critical technology for patients.

By way of background, AMRPA is the national trade association representing more than 700 inpatient rehabilitation hospitals and units (referred to by CMS as Inpatient Rehabilitation Facilities, or IRFs). IRFs play a unique and critical role in providing hospital-level rehabilitation care to beneficiaries requiring ongoing and intensive care following acute care hospitalization, such as patients recovering from stroke, traumatic brain injury, and traumatic spinal cord injury, among other serious conditions. Given the complexity of patients requiring inpatient rehabilitation, we strongly support modernizations to Medicare coverage policy to ensure these patients are able to access and benefit from the most current technology that supports independent living.

For those reasons, AMRPA agrees with NCD’s finding that these systems are reasonable and necessary for Medicare beneficiaries using Group 3 power wheelchairs when they (1) perform weight-bearing transfers in the home to/from their wheelchair, with or without the use of caregiver assistance or assistive technology, and (2) undergo a specialty evaluation by a practitioner with specific training and experience (e.g., physical and/or occupational therapists) in rehab wheelchair evaluations. This proposal is aligned with AMRPA and our coalitions’ longstanding advocacy, and we believe this will be an important step forward in advancing the Administration’s health equity goals. As CMS looks to finalize this policy, we also urge two important inclusions: (1) extending coverage to improve reach and line of sight to support shoulder, upper spine, and neck integrity, and (2) expanding access to seat elevation for users of Group 2 power wheelchairs. We address each of these refinements in turn.

Coverage to Improve Reach and Line of Sight: First, AMRPA would support the extension of seat elevation coverage to Group 3 wheelchair users who would benefit from the increased reach and improved line of sight provided by these systems. We believe current research (complemented by expert opinion and patient-centered outcomes data) all demonstrate how seat elevation delivers these critical benefits to Group 3 wheelchair users. While CMS limited its own evidence review to clinical studies regarding transfers, AMRPA was pleased to see numerous commenters to the initial NCD offer evidence supporting the medical benefit for reach and neck positioning/line of sight in the built environment (for example, the fact that improved reach and line of sight through seat elevation makes the performance of mobility-related activities of daily living safer for wheelchair users). In all, reach and line of sight are critical and necessary to improving wheelchair users’ health, safety within the home, and quality of life, and AMRPA urges CMS to ensure that the final NCD reflects this.

Coverage for Group 2 Power Wheelchair Users: As we understand CMS’ current position, the agency is considering the inclusion of users of Group 2 power wheelchairs with respect to seat elevation coverage policies. AMRPA would strongly support this inclusion. While AMRPA recognizes that Group 2 and Group 3 wheelchair users typically have different medical needs and that different standards apply to Group 2 and Group 3 wheelchairs, AMRPA believes there is an important population of Group 2 wheelchair users with the type of mobility limitations that would make seat elevation reasonable and necessary for their medical needs. In the spirit of health equity and access, we urge CMS to adopt a policy that would not limit these patients’ access to seat elevation solely because they do not fit into the specific diagnoses that fit under the Group 3 coverage criteria.

As AMRPA members across the country report, seat elevation can help Group 2 power wheelchair users safely transfer to/from their power wheelchair and gain access to the vertical environment to perform routine activities, like toileting, bathing, and grooming. Seat elevation provides a basis for level transfers to reduce upper extremity strain during lateral transfers and lower extremity strain during “sit-to-stand” transfers. Providing coverage of seat elevation (with a height of at least 6 feet) for these patients would facilitate their ability to cook, clean, and do other daily activities – which would provide especially crucial support for Group 2 power wheelchair users who live alone and/or are deemed a high fall risk. AMRPA urges CMS to take these beneficiaries into account as it considers expanding seat elevation coverage for these beneficiaries.

Finally, AMRPA aligns itself with the ITEM Coalition in seeking clarity on CMS’ proposed limitations on “weight-bearing transfers” and related terminology, as we believe well-defined criteria are critical to ensure that all beneficiaries who would benefit from seat elevation are able to access coverage under the final NCD decision.

In closing, we commend CMS for its much-needed action in this area of the Medicare program and urge the agency to make the key refinements outlined above to fully promote patient-centered coverage criteria.

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March 13, 2023

Centers for Medicare & Medicaid Services Department of Health and Human Services
Submitted electronically at CMS.gov

Re: Proposed National Coverage Determination for Power Seat Elevation Equipment on Power Wheelchairs

To Whom It May Concern,
I want to thank CMS for their proposal and that the evidence is sufficient to support the classification of seat elevation equipment on Group 3 power-operated wheelchairs as DME. As a long-time member of the Complex Rehab community, I have advocated for coverage of these systems as well as power standing systems under Medicare. I am submitting the following comments on behalf of myself an interested party who has over 20 years of rehab experience in sales, marketing, manufacturing, and industry leadership.
I am basing these comments on outcomes and research that has been done through U.S. Rehab, a division of VGM Group Inc., and University of Pittsburg, Department of Rehabilitation Science & Technology. This partnership used the Functional Mobility Assessment (FMA) and associated Uniform Data Set to collect data, deidentify and analyze. The Functional Mobility Assessment (FMA) research being collected has amassed over 500,000 individual pieces of data from people with disabilities. The collection has come over 7 years and has shown great evidence of seat elevation and its medical benefits. The University of Pittsburgh, Department of Rehabilitation Science & Technology have collaborated with VGM/U.S. Rehab on this project to systematically describe the population of people with disabilities who need and use Mobility Assistive Equipment (MAE) as well as assess the outcomes post provision of properly provided devices. This is carried out through the Functional Mobility Assessment & Uniform Dataset (FMA/UDS) Registry that currently comprises of over 13,000 cases of people with disabilities who use Mobility Assistive Equipment (MAE).
A published article in Assistive Technology the Official Journal of RESNA With over 1733 power wheelchair users and comparative cases who had a seat elevator (n=265) the evidence shows improved overall functional mobility, transfer, reach, and reduce falls. With this large data and strong showing of statistical evidence I am pleased to support the coverage criteria for transfers and respectfully request a review of the evidence in support of extending coverage for the purpose of reach and line of sight. With a second published study in Archives of Physical Medicine and Rehabilitation with over 4743 cases of individuals who use mobility assistive equipment. The study Authors found the most significant predictor of variable in FMA scores was device type. This was likely because the device itself is specific and fitted for people with disabilities as they engage their access to education, work, and social life; increase their independence; and enhance their participation in their communities.
The Two studies show that satisfaction is achieved when functionality is achieved. As those using power wheelchairs can integrate more in their communities and function at a higher level in performing mobility related activities of daily living (MRADLs) they are safer and more satisfied. Reducing negative occurrences like falls and hospital readmittance along with facilitating employment.
Summary of Recommendations:
As CMS prepares its final National Coverage determination for release in May 2023, I urge the agency to:
1. Finalize the proposed Benefit category Determination holding the power seat elevation systems are primarily medical in nature and are considered durable medical equipment under the Medicare benefit: and finalize the proposed coverage determination holding that these systems are reasonable and necessary for medical beneficiaries who use Group 3 CRT power wheelchairs to perform transfers for the purpose of performing or participating in (MRADLs).
2. Include coverage for Medicare beneficiaries who need seat elevation to improve there reach and line of sight to support shoulder, upper spine, and neck integrity while performing or participating in MRADLs.
3. Include coverage of seat elevation for medical beneficiaries who use Group 2 CRT power wheelchairs in the final NCD.
4. Provide important clarifications to the proposed NCD, including further detail regarding “weight-bearing transfers,” beneficiaries using patient transfer devices, and the specific criteria for specialty evaluations.
I strongly support the proposed determination, with the revisions and inclusions noted above. This will that all beneficiaries receiving medical benefits for seat elevation are able to access coverage under the finalized NCD.
Again, thank you and I applaud CMS for recognizing the significant clinical evidence and overwhelming public ensure support for covering seat elevation in CRT power wheelchairs. I encourage CMS to finalize the coverage decision to ensure all beneficiaries who can benefit from seat elevation are able to access this technology under the Medicare program.

Sincerely,

Greg A. Packer

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Among the many cruelties of [PHI Redacted] is its brazen robbery of the everyday abilities that we all take for granted - walking, getting dressed, feeding yourself, talking, and eventually, swallowing and breathing.

My ever-patient wife is my primary caregiver and dresses, feeds, and bathes me. I use an eye gaze device and a banked voice - both financed in great part by [PHI Redacted] - to communicate (this message is an example ). My motorized wheelchair provides the mobility that my legs no longer can.

The wheelchair - along with another tool known as a sit-to-stand - plays a critical role in enabling the many transfers required each day: getting up, going to the bathroom, going to bed, etc.

And, in my case, THE essential tool on my wheelchair, other than its motor, is it’s seat elevation system. Without that technology, my wife and I could not execute the many transfers necessary in an ordinary day. Fortunately, my secondary medical insurer recognized the essential nature of this technology for persons with neuro-muscular diseases, and covered it in full.

Sadly, [PHI Redacted] patients reliant on Medicare alone are currently denied coverage for seat elevation systems. I strongly encourage Medicare to change its current policy and offer coverage for seat elevation systems to those with [PHI Redacted] and similar disabilities, as well as to others with a clear need for such empowering technology.

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Introduction

The American Association for Homecare (AAHomecare) is the national association representing durable medical equipment, prosthetics, orthotics and supplies (DMEPOS) suppliers, manufacturers, and other stakeholders in the homecare community. Our members include manufacturers and suppliers of manual and power wheelchairs, including complex rehab power wheelchairs. Complex rehab technology (CRT) devices include medically necessary and individually configured manual and power wheelchairs, seating and positioning systems, and other adaptive equipment such as standing devices and gait trainers. Our members are proud to be part of the continuum of care that assures beneficiaries and other patients receive cost effective, safe, and reliable home care products and services.

AAHomecare strongly supports Medicare’s proposed coverage of seat elevation as detailed in the formal September 2020 coverage request submitted to CMS by the ITEM Coalition. Seat elevation is critical to mobility-related activities of daily living (MRADLs) in the home. Seat elevation improves transfers and reaching, reduces falls, and reduces or eliminates neck and spine injuries from power wheelchair use. Seat elevating systems provide medical and functional benefits while reducing health care costs by decreasing falls, skin breakdowns, muscle contractures and other avoidable medical complications of long term or permanent wheelchair use. Power seat elevation systems have been available for years and are covered by most other payers, besides the Medicare program. It is high time for the Medicare Program, as the largest health care insurer in the country, to provide coverage for these important systems.

AAHomecare is pleased to submit comments on the Centers for Medicare and Medicaid Services’ (CMS’) Proposed Decision Memo on Seat Elevation Systems as an Accessory to Power Wheelchairs (Group 3). Seat elevation systems allow for wheelchair bound patients to safely participate in activities of daily living with or without additional assistance, allowing them to live a more independent life. Being able to safely perform or participate in activities of daily living would minimize potential serious injuries, which would, in turn, reduce the frequency of emergency department visits or hospitalizations.

CMS’ Proposed Decision

CMS is proposing that power seat elevation equipment on Group 3 power wheelchairs falls within the benefit category for durable medical equipment (DME). CMS is proposing that the evidence is sufficient to determine that power seat elevation equipment is reasonable and necessary for individuals using power wheelchairs when the following conditions are met:

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March 17, 2023

Centers for Medicare & Medicaid Services
Submitted electronically at https://www.cms.gov/medicare-coverage-database/view/national-submit-public-comment.aspx?DocID=309&commentDocType=nca&fromPage=tracking&

Re: CAG-00461N- Proposed National Coverage Determination for Power Seat Elevation on Power Wheelchairs

To Whom it May Concern:

I am writing on behalf of National Seating & Mobility (NSM) a North American provider of Complex Rehab Technology (CRT) with history and experience serving individuals with complex needs for almost 30 years. CRT products are a specialized subset of technology classified within the Durable Medical Equipment (DME) category. These items include medically necessary and individually configured manual and power wheelchairs, seating and positioning systems, and other adaptive equipment such as bathing equipment, standing devices, and gait trainers.

NSM strongly supports the written comments submitted by the ITEM Coalition, The Clinician Task Force, The National MS Society, Team Gleason, NCART, AAHomecare regarding the CMS Proposed Decision Memo on Seat Elevation Systems as an Accessory to Power Wheelchairs (Group 3).

Specifically, we want to call attention to recommendations that the Nationally Covered Indications for Power Seat Elevation Equipment on Power Wheelchairs proposed in Appendix B be revised as follows:

Effective for services performed on or after [Month/XX] [20XX], power seat elevation equipment is reasonable and necessary for individuals using complex rehab power wheelchairs with a medical or functional need for vertical movement to allow the beneficiary to perform or obtain assistance to participate in MRADLs in the home when condition 1, 2, and 3 are met and, for Group 2 complex rehab power wheelchairs condition 4 is met, and for Group 3 and above complex rehab power wheelchairs, condition 4, 5, and/or 6 is met:

1. The beneficiary meets all the coverage criteria for a power wheelchair described in the Power Mobility Device LCD; and
2. A specialty evaluation was performed by a licensed/certified medical professional, such as a physical therapist (PT) or occupational therapist (OT) or practitioner who has specific training in rehabilitation wheelchair evaluations of the beneficiary’s seating and positioning needs. The PT, OT, or practitioner may have no financial relationship with the supplier; and
3. The wheelchair is provided by a supplier that employs a RESNA-certified Assistive Technology Professional (ATP) who specializes in wheelchairs and who has direct, in-person involvement in the wheelchair selection for the beneficiary.
4. The individual performs transfers to/from the power wheelchair while in the home, using their upper extremities and/or their lower extremities. Transfers may be accomplished with or without caregiver assistance and/or the use of any type of assistive equipment (e.g., cane, crutch, walker, sliding /transfer board, transfer assist handles, trapeze, transfer/pivot disk, sit-to-stand device, patient lift/transfer system, etc.).
5. The individual is at high risk for repetitive strain injury or has limited range of reach of the upper extremities, which prohibits performance of or participation in one or more MRADLs from a static seat height due to limited upper extremity strength, limited upper extremity range of motion, deformity, and/or short stature, and
   a. The beneficiary does not have sufficient balance, strength, range of motion, and/or endurance to stand and participate in or perform their MRADLs; and
   b. The beneficiary is able to participate in or perform their MRADLs from a seated position in the home with the provision of a power seat elevation system.
6. The individual has limitations in vision, neck range of motion and/or posture induced neck reflex activity, and cervical hyperextension of the neck:
   a. Prohibits the performance of or participation in one or more MRADLs from a static seat height; or,
   b. Results in the beneficiary losing contact with their alternative drive input device to operate their power wheelchair and/or power seat functions from a static seat height; and,
   c. The beneficiary is able to operate their power wheelchair, and power seat functions to participate in their MRADLs from a seated position in the home with the provision of a power seat elevation system.

We also request that CMS consider the recommended revisions to the National Coverage Determination for Mobility Assistive Equipment to support the NCD for Power Seat Elevation Equipment, as originally proposed in the ITEM Coalition’s NCD Request for Reconsideration in September 2020.

Lastly, we strongly recommend CMS work with the DME MACs and stakeholders to take the additional steps required to establish coverage criteria necessitated by the National Coverage Determination for Power Seat Elevation Equipment in the Power Mobility Device and Wheelchair Options/Accessories Local Coverage Determinations (LCDs) and their associated Policy Articles to effectuate this change accordingly.

Please refer to the formal written comments submitted on behalf of NCART for full detail and additional comments supporting the above.

Thank you again for your consideration of coverage for this extremely important technology. Having access to Power Seat Elevation will make a world of difference for individuals who would benefit from it by both allowing for/enhancing independence and by preventing certain medical complications.

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TO: Centers for Medicare & Medicaid Services (CMS)
FROM: ALS Advocate Comments Collected by The ALS Association
SUBJECT: Proposed National Coverage Determination for Power Seat Elevation on Power Wheelchairs (CAG-00461N)
DATE: March 17, 2023

Mrs. Sheila M.

CMS Seat Elevation Comment    For years, my sisters and I had to pick my father up from a wheelchair and put him into bed, onto the toilet, into the car, or any other location other than his wheelchair. Any device that could've made this task. Easier is mandatory. Any device that could assist a patient suffering with ALS or assist their caregiver

In providing optimal care should be mandatory. The disease is brutal enough, to then have to fight for what is needed is an outrage. I put yourself in someone else's shoes just for a minute and you wont think twice about voting yes for this simple request.

Date Submitted 2/22/2023

Elizabeth H

CMS Seat Elevation Comment    Imagine you are YOU, right now, with your intellect and emotions and words to say, yet each of your muscles are slowing melting away with progressive loss of function until your diaphragm gives out and you can't breathe anymore. That is ALS. It is truly one of the most horrible diseases that ends up 100% in death, guaranteed.

While fighting this disease, it is a gamechanger for Medicare to remove an additional fight for fundamental equipment that prevents injury and supports quality of life during at times a rapid decline.

Adding seat elevation in power chairs will enable me to transfer my husband into a hospital bed and back without injury; it enables me to lower the chair to get under tables so he can sit and join our family and friends at the table. Covering seat elevation prevents injury of caregivers and folks with ALS.

Think of yourself or your partner or child in that chair. Is adding power elevation truly that hard? Negotiate a price so medical companies have a reasonable write off, and make the approval process FAST. Folks with ALS don't have much time. This is a reasonable ask. Please do the right thing.

Date Submitted 2/25/2023

Kari F.

CMS Seat Elevation Comment    My Dad had ALS for about 4yrs. When he passed away he looked like a holocaust victim, tiny, frail, skin and bones. During his battle we had to try multiple types of chairs. A power chair w elevation would have been so helpful in getting him up from the chair. It would have decreased the risks of skin tears while trying to get him up. It would have helped prevent hurting his arms while getting him up. It would have helped make things more comfortable for him. Help AlS patients and their care givers. Approve the elevation to the power chairs.

Date Submitted 2/22/2023

Denise B.

CMS Seat Elevation Comment    An elevated seat would give ALS patients more independence. They could raise their seat to transfer into bed easier. Seat elevation in power wheelchairs would help care givers of ALS patients experience less back and shoulder pain when lifting patients. My mother's shoulder is permanently out of place due to the constant care of my father.

Watching my father pass away from this horrible disease was something that is difficult to put into words, but looking back, I see how having a power wheelchair with seat elevation would have made him feel less dependent on my mother and his care givers. It's bad enough to live with ALS, but to have to always depend on other people for your care makes it worse.

I BEG YOU TO PLEASE COVER THE COSTS OF SEAT ELEVATIONS EQUIPMENT FOR POWER WHEELCHAIRS!!

Date Submitted 2/22/2023

Mr. John Werner

CMS Seat Elevation Comment    Care givers have it bad enough when trying to hoist a man whose limbs no longer work. Just imagine trying to get transport help when you need to be lifted from a low chair to higher seating !

Date Submitted 2/22/2023

Bettina K.

CMS Seat Elevation Comment    Lost My husband toALS. Seat elevation in the wheelchair was imperative.

Date Submitted 2/22/2023

Lyn C.

CMS Seat Elevation Comment    I have 2 friends who have ALS, and my maternal grandmother died from this debilitating terminal disease. There are no words that amply describe the day to day struggles of patients and caregivers go through. This is just one of the many basic necessities these folks deserve.

Date Submitted 2/23/2023

Mr. Paul V.

CMS Seat Elevation Comment    Hi,

We (but mostly our Mom) cared for our dad during his five years of living with ALS and having a wheelchair was helpful but having elevation would've made her life a lot easier (and his) and so I think this would be a wonderful thing to see happen (although my mom said her arms got very strong from lifting him).

Thank you,

Date Submitted 2/23/2023

Ms. Dortha Meadows

CMS Seat Elevation Comment    That's awesome. Seat elevation in a wheel chair helps caregiver get them out of chair.

Date Submitted 2/22/2023

Dee C.

CMS Seat Elevation Comment    My mother paid for the seat elevation seat when she was diagnosed with ALS. This made it easier to care for her when washing her hair-we could wash her hair at the kitchen sink and she was more comfortable. It also saved my back not having to lean so far over to care for her feet. She enjoyed it to be able to see people at their height. The electric seat elevation also gave her independence and control.

Date Submitted 2/23/2023

Lorelle J.

CMS Seat Elevation Comment    My husband died from ALS in 2010. Seat elevation in his wheelchair would have made both of our lives easier. It would have helped in moving him from chair to toilet, etc. I wasn't strong enough to lift him from the chair. Please do whatever you can to make the lives of folks living with ALS easier. There's so little that can be done for them!

Date Submitted 2/22/2023

Lee S.

CMS Seat Elevation Comment    Arms too weak to assist getting up;

Stuck sitting is like torture: bottom consequently soring,; back becoming stiff and neck stiff and rigid due to lack of uptight walking ; increased psychological and physical weight of strain on my wife owning to increased tethering to elevation assistance; declining feet and foot strength due to being noticeably less ready standing engagement.

Hardship at coming to a stand to then partake and engage in many fronts feels like an exponential hindrance that is tilting directly to a tangible, and sticky, sting of despair.

Date Submitted 2/24/2023

Amy Gutierrez,MD

CMS Seat Elevation Comment    Many of my patients need this system to be able to complete their activities of daily living and have as much independence as possible. This allows them to live a more robust quality of life

Date Submitted 2/22/2023

Andrea Poehling

CMS Seat Elevation Comment    Thank you for proposing that Medicare cover costs of seat elevation equipment for power wheelchairs. This issue is important to me because my loved one lived with ALS and his wife (also a loved one of mine) served as his caregiver. He was fortunate to have had seat elevation on his power wheelchair. This enabled him a measure of independence, even when the disease advanced. He was able to prepare his own meals and take care of his grooming. This alleviated some of the considerable responsibility and stress on his caregiver, who managed his care and the running of the household. The independence that the seat elevation equipment provided was beneficial in practical and physical terms, while also allowing them to focus on their relationship during his final years. I sincerely hope that Medicare covers these costs so that others living with this terrible disease will have their lives made a bit easier. Thank you for your consideration.

Date Submitted 2/24/2023

Bridget Hunt

CMS Seat Elevation Comment    This would be very helpful thank you so very much I hope you come through with this

Date Submitted 2/25/2023

Paula Chevrier

CMS Seat Elevation Comment    As an aged caregiver myself, seat elevated equipment helps my family member continue to maintain some independence as well as preventing caregiver injury. Thank you.

Date Submitted 2/25/2023

John M.

CMS Seat Elevation Comment    I am the primary caregiver for my wife and having a wheelchair that gets to counter height would be a great benefit in her struggle with daily mobility tasks.. Please support approval of height adjustable wheelchairs

Date Submitted 2/23/2023

Danielle Fitzpatrick

CMS Seat Elevation Comment    Seat elevation in power wheelchairs would decrease the likelihood of shoulder and back injuries in caregivers. As a former caregiver and a physician, I strongly advocate for any assistive device that can not only improve the quality of life and safety of the patient, but also the caregivers, who often sacrifice themselves and their own bodies in service of their loved one. Moreover, seat elevation would optimize the patients' ability to safely transfer, as well as position themselves in the optimal way for communication (in the case of using an eye gaze device, for example), as well as to improve quality of life in their ability to perform ADLs.

Date Submitted 2/23/2023

Sharon Hallman

CMS Seat Elevation Comment    I treat people with ALS and other neuromuscular diseases and recommend equipment to manage the rapid progression of weakness and the subsequent mobility problems. A seat riser on a wheelchair is an essential feature for many people with ALS.

1. When legs are weak it allows the user to raise the surface so they can stand to get in and out of the chair safely without requiring an additional caregiver.

2. If shoulder weakness is prevalent, it allows the user to reach things at counter height, get something from the refrigerator, turn on lights etc. again minimizing the need for a hired caregiver to accomplish these small fears of independence.

3. In later stages of the disease, caregivers can tend to the physical needs of the individual such as managing bowel and bladder, feeding tube etc. at a safe height.

Please support Medicare coverage for seat risers on power wheelchairs.

Date Submitted 2/23/2023

Lyndal B.

CMS Seat Elevation Comment    I currently live in assisted living and the facility has no openings under the sinks, so without being able to elevate my seat I cannot reach the faucet handles. Because of this I have to pull myself up and try to balance there (which is very dangerous for me as I have only one good leg to offer support and my balance is nil) to do any chores or personal hygiene at both sinks. Having elevation on my wheelchair would also allow much more independence to get things out of cabinets and clothes off hangers.

Date Submitted 2/23/2023

Richard Jahn

CMS Seat Elevation Comment    This is very important for people with ALS as you get weaker from the Disease you can no longer lift.

Date Submitted 2/22/2023

Kim Conforti

CMS Seat Elevation Comment    Seat elevation will help with quality of life physically and mentally people would be able to position themselves differently at times when needed and also become eye level with others. It will also help caregivers from having to always lift the patient and may be able to keep care at home longer depending on the caregivers' abilities

Date Submitted 2/22/2023

Jeannie D.

CMS Seat Elevation Comment    My mother passed before the government step in to help and I wish she would have received the help that ALS patients are getting today. And yes there is still a lot of work to be done. But if you have the power to help them get through it please help. Unless you have actually known or have talked to a ALS patient you have no idea what they go through every day if they can get some relief from the pain that they endure every minute please help thank you JEANNIE D

Date Submitted 2/23/2023

Amy White

CMS Seat Elevation Comment    ALS is 100 percent fatal. Daily tasks become unable to be performed without help. And them completely. Everything ALS related should be 100 percent paid. These patients are living a life of hell

Date Submitted 2/22/2023

Mrs. Judy C.

CMS Seat Elevation Comment    While my sister is in heaven with her Heavenly Father now, the seat elevation in her power chair Would have been a true blessing. Going forward for others this is crucial for their care.

Date Submitted 2/22/2023

Cindy H.

CMS Seat Elevation Comment    Please support the seat elevation in power wheelchairs. My sister-in-law had ALS and it was devastating. To give them a little bit more ease is what those effected with ALS deserves. Please, please pass this coverage.

Date Submitted 2/22/2023

Judith K.

CMS Seat Elevation Comment    Beginning in July 2002, I started falling down for no reason. After 9 months of testing with various doctors, I was diagnosed with ALS on 4/17/2003. I would be able to work until December 2004. At that point, I filed for SS DISABILITY. I was accepted at that time but had to wait 6 months before I would get paid. I was slowly losing mobility. I received my first electric wheelchair in April 2005. We have done several things to update the house for my wheelchair, which at that time I had to pay out of pocket. We bought a new van to accommodate the new wheelchair. Expenses were astronomical until we realized that we could get help.

When my husband retired in January 2016, I was forced to get Medicare. That was helping with medical expenses. We were introduced to ALS Association and they have helped tremendously with other costs.

I have been somewhat stable over the last 15 years with little changes. Probably in the last 10 years, there were not any changes. In April I plan to celebrate 20 years with ALS.

I didn't get married until I was 40 and was 45 when I was diagnosed. My husband is WONDERFUL as he has helped me every day and didn't leave me. He lived up to "in sickness and in health". He does EVERYTHING for me.

I am truly BLESSED.

Date Submitted 2/23/2023

Bonnie P.

CMS Seat Elevation Comment    I was a wife/caregiver for [PHI Redacted] who passed away from ALS in May of 2020. When his first wheelchair was ordered, we could not afford the extra 1,000 dollars to add the seat elevation mechanism. This was the only wheelchair he ended up owning, as he died after almost 8 years. He still was not ready to get a new chair, according to Medicare, after he became completely unable to stand. Or to get out of the chair without a sit to stand machine. He would have benefitted greatly from this mechanism, as his feet and lower legs became constantly swollen. We had to use a leg pump apparatus to bring down the swelling. If he had been able to stand with assistance, this might not have been necessary. Also, it would've been something he could have done by himself, and not another thing that I needed to do for him. You cannot overlook the importance of what a caregiver goes through to take care of their person with ALS. This would have greatly improved his shortened life.

Date Submitted 2/22/2023

Michael Hengel

CMS Seat Elevation Comment    I have ALS in my family genes. Sitting in a wheelchair for the last months of life is alienating because height is important in conversation, doing simple tasks(in a home not perfectly wheelchair adapted), and even in helping caregivers to transfer from wheelchair to other device.

Date Submitted 2/22/2023

Judy Grimes

CMS Seat Elevation Comment    I have a sweet friend who has been diagnosed with ALS that can use any and all help she can get!!! She's young, newly married (8 yrs) and is just devastated by this horrible disease. Her husband has had to quit his job to stay home and take care of her.

Date Submitted 2/22/2023

Shruti Modi

CMS Seat Elevation Comment    Seat elevation in power wheelchairs are proven to be useful and beneficial for those living with ALS. The diagnosis of this disease is devastating for not only that individual, but also their caregivers. Most importantly, seat elevation features help to prevent injuries, for those with ALS and their caregivers alike. In addition, after having so much of their functionality affected, being able to use seat elevation to perform daily living activities can help those living with ALS feel some semblance of independence and productivity. It is useful for those with limited mobility, and can reduce the strain on both parties when they need to be transferred from the wheelchair to other surfaces, such as beds and chairs. The majority of individuals who are diagnosed with ALS are faced with overwhelming financial stress, and cannot afford professional in-home medical care to help with these things that many take for granted. As such, seat elevation in power wheelchairs is incredibly necessary and would provide significant benefits to those living with ALS, as well as their caregivers.

Date Submitted 2/22/2023

John Marshall

CMS Seat Elevation Comment    Lifts for wheelchairs provide freedom which is what the USA is supposed to be about. So, Congress, stop the oil subsidies and tax cuts for oligarchs and get with the caring crowd! Cover wheelchair lifts today!

Date Submitted 2/22/2023

Tyrone Stewart

CMS Seat Elevation Comment    This would end accidental drops and slips

Date Submitted 2/22/2023

Adriana B.

CMS Seat Elevation Comment    My husband has ALS for 6 years and in the beginning a lifting power wheelchair would had helped him and myself a lot. The pALS is already deprived of so much but being in a social world to be able to look eye level, in a way can make he/her feel a little more inclusive. For me this is one of the most important reasons. Be able to still feel part of a world that in a very short time will be taken away from he/her.

Date Submitted 2/22/2023

Mr. John D.

CMS Seat Elevation Comment    When my Grandfather [PHI Redacted], my mother [PHI Redacted] and her siblings, and 2 first cousins needed absolute help getting up and down after being diagnosed with ALS. I saw first hand the importance of seating elevation. As for my mother and Uncle [PHI Redacted], their electronic elevation chair was not only very helpful for the patient, but also extended their very last little bit of feeling independence.

Date Submitted 2/22/2023

Phyllis W.

CMS Seat Elevation Comment    My dearest friend Val, who is like a little sister to me has ALS and I know if she had a wheelchair with the feature to elevated her in her seat it would enable her to be able reach do many thing that she can't teach now.

When she was find raising a few months ago my husband and I donated $500 to support her and her cause. So let's help those who have ALS get the best equipment possible to make their lives easier.

Thank you so much.

The Big Sister, Phyllis

Date Submitted 2/22/2023

Mr. Russell T.

CMS Seat Elevation Comment    It's wonderful that Medicare is proposing to cover costs of seat elevation equipment for power wheelchairs! This is absolutely necessary for patients and caregivers alike. My mother had ALS, and I cared for her until her death. Having elevation equipment would have made our lives much better.

Date Submitted 2/22/2023

Jacalyn C.

CMS Seat Elevation Comment    Seat elevation is integral to quality of life. We use it to help my husband brush his teeth, sit at the same level with us at the kitchen counter, rise up to empty his urinary catheter bag, be on the same level as those who are standing in a social situation, and to make it easier on medical personnel for examinations and PEG and suprapubic catheter replacement. Without this functionality, I cannot imagine how we would get through the activities of daily living.

Date Submitted 2/22/2023

David R.

CMS Seat Elevation Comment    As a person experiencing ALS firsthand, I cant express how important seat elevation is for maintaining a basic quality of life. Thank you for your support of this proposal.

Date Submitted 2/22/2023

Michela L.

CMS Seat Elevation Comment    The ability for an ALS patient to elevate in their power wheelchair is one SMALL way of allowing them some sense of "normal" life in a world that is no longer normal. I paid out of pocket for the seat elevation on my husband's PWC. It allowed him to participate at "eye level" in activities with others. Such a key component to his quality of life! ALS is an incredibly expensive disease to have. Please, please, please make this a covered expense under durable medical equipment.

Date Submitted 2/22/2023

Mrs. Robbin M.

CMS Seat Elevation Comment    Please let people suffering with ALS have chair elevation power chairs. My husband died of this terrible disease. We were so lucky that his insurance allowed him to have a chair with elevation and it was so helpful in the everyday care for him. If the person has a slow moving case it would allow that person more independence. But in a fast moving case it is an invaluable tool in the everyday care for the sufferer and could allow family and friends to help rather than hiring care workers.

Date Submitted 2/22/2023

Barbara S.

CMS Seat Elevation Comment    I feel this is very important to me because it would help my brother tremendously. He suffers from this terrible disease. If would help my brother get around at home better

Date Submitted 2/23/2023

Jacquelyn L.

CMS Seat Elevation Comment    My brother in law has been immensely helped having an elevated wheelchair!!!It allows him to join with others at many levels Please offer this to all ALS patients. Thank you.

Date Submitted 2/24/2023

Joseph Clemente

CMS Seat Elevation Comment    I follow a couple impacted by ALS on social media and I feel like this will help the individual who am has the disease and his caregiver.

Date Submitted 2/22/2023

Elizabeth R.

CMS Seat Elevation Comment    I'm a 61 yo mother of a 31 yo son who has been living with ALS for 30 years. I need my seat elevation in my chair so that when I'm in a group of people, standing & talking, I am able to elevate and talk with them without them having to bend down to make eye contact. It's not fun staring at waistlines when you're talking!

It's important to caregivers that I can elevate so it's easier to brush my teeth, put on make-up etc. without them bending over, saving them physical discomfort!

Having seat elevation is important to me because I can still be part of the conversation, when it's time for pictures I can be at nearly the same the same height as those around me.

Please cover seat elevation in wheelchairs! Thank you,

Date Submitted 2/22/2023

Wayne Sullivan

CMS Seat Elevation Comment    Seeing my close friend with ALS 100% incapacitated is brutal. His wife struggles with getting him in and out of his chair. Any mechanical assistance would be fully justified.

Date Submitted 2/22/2023

Ms. Joan Brown

CMS Seat Elevation Comment    Please approve the proposed coverage of seat elevation equipment for power wheelchairs for ALS patients. Seat elevation in power wheelchairs will improve the quality of life for me as a caregiver of loved one living with ALS in many ways. It is very difficult to lift and raise my loved one from their chair.

Seat elevation will greatly assist me, as a caregiver, when transitioning my loved one from the seat to the bathroom, to the bed, to the car, anywhere they need to be. It will help me to retain my health (saving my back!) while I continue to assist my loved one.

It would also preserve what little dignity my loved one has left due to the limitations created by ALS. They will be more comfortable, retain some independence, better able to access/reach for items needed and be more mobile thanks to the assistance of seat elevation. The seat elevation equipment will also reduce the risk of injury for my loved one as well.

Date Submitted 2/22/2023

Wil M.

CMS Seat Elevation Comment    I am a person living with ALS and to seat elevation in a power wheelchair would be amazing. I can be on level with my family when they are standing. I don't have to look up and they don't have to look down. I can't thank you enough for doing this. It will be so helpful to me and my caregiver to have the ability to go up and down.

Thank you!

Date Submitted 2/22/2023

Ricky J.

CMS Seat Elevation Comment    I have ALS and cannot understand why Medicare would have to think about adding the elevation part of a wheelchair, if you are wheelchair bound and have to reach into a upper cupboard or anything beyond your reach a elevation seat is crucial for daily living. Ricky J

Date Submitted 2/22/2023

Mary H.

CMS Seat Elevation Comment    Please cover! This is mandatory for optimal treatment! My brother died of ALS in 2017. Thank you!

Date Submitted 2/22/2023

Candace Menzel

CMS Seat Elevation Comment    Seat elevation is vital for everyday management in dealing with this terrible disease. I truly hope Medicare will make it official and start covering this expense.

Date Submitted 2/22/2023

Linda S.

CMS Seat Elevation Comment    Seat elevation in power wheelchairs would have been a back saver for me as a caregiver of two loves of my life, my dad died from ALS my husband diagnosed shortly after and died from ALS both within five years. Their inability to lift themselves up had been taken from them by the disease. One must remember that people with ALS do not loose the ability to process what is happening to them. They are helpless in their bodies and realize what their caretakers must do repeatedly for them day after day. Us caregivers must lift our loved ones who are dead weight several times a day. Lift them for bed, toileting, bathing, and repeat. A lift elevation boost will save our backs and make it easier for the patient to accept the help more readily knowing that it is a little bit easier for their caregiver to help them. You cant possibly understand a 24/7 full time job day after day lifting and pulling until you've done it yourself. Please help our ALS patients and their caregivers by making these lift boost seats a reality.

Date Submitted 2/22/2023

Ms. Andrea Byrne

CMS Seat Elevation Comment    For five years I was a caregiver for a person dear to me who was living with ALS. For thirteen years I worked in Care Services with people living with ALS. In both circumstances I saw how important the seat elevation aspect of a power wheelchair was for them to continue to do things for themselves, to feel part of conversations, and to have a better sense of dignity. In addition, it made life easier for the caregivers to assist them with feeding and other necessary activities. Please provide Medicare coverage the seat elevation for power wheelchairs. It is critically important. Thank you.

Date Submitted 2/22/2023

Robert Quisenberry

CMS Seat Elevation Comment    Seat Elevation in wheelchairs is so important for maintaining the accessibility & dignity of users in several ways. First, it allows the wheelchair user to elevate high enough to access higher cabinets and shelves at home and in stores, etc. Secondly, in social settings it allows the user to elevate above "butt" level of people that are standing so that everyone is not looking down on the user when talking. Any element that provides some normalcy when in a wheelchair really matters to the users and their caregivers.

Date Submitted 2/22/2023

Valerie Todd

CMS Seat Elevation Comment    Seat elevation for power wheelchairs is essential to the independence for ALS patients. This feature enables the patient to adjust to different environments both at home and away. At home, the patient is able to reach countertops, use the refrigerator, use a mirror to comb their hair, get clothes from their dresser, or comfortably look out a window to name just a few. For the caregiver, the elevation eases the care by being able to raise the patient for hair washing, dressing, and assisting at mealtime. Providing a level of independence to an ALS patient is a step in maintaining their dignity.

Date Submitted 2/24/2023

Jared N.

CMS Seat Elevation Comment    Seat elevation in power wheelchairs has many benefits, physically and mentally, both for the wheelchair user and caregivers.

Physically, it allows the power wheelchair expanded mobility to complete more tasks on their own. They are able to reach higher items that normally would be out of reach. This would allow the wheelchair user to complete a task instead of relying on a caregiver, freeing up time for both. Also, it allows caregivers to take care of the person in the wheelchair easier. My mother would have my father use the seat elevation in a higher position to more easily trim his toenails.

I believe the bigger advantage of seat elevation is the mental improvements. My father would use the seat elevation function frequently when his grandchildren were playing outside so he could see them easier. While he was inside, if he sat up higher, he had a better view of the yard and could watch them, which just made his day so much better. Also, raising oneself to be able to be more eye to eye with them while they are talking to you is mentally better than constantly being looked down on while conversing.

Date Submitted 2/28/2023

R Strobel

CMS Seat Elevation Comment    THIS CAN REALLY HELP ME. I NEED THIS

Date Submitted 2/22/2023

Cindy B.

CMS Seat Elevation Comment    My father died from ALS 13 years ago. We purchased a recliner with a seat elevation system so that it would be easier for him, and for us, to get him in and out of a sitting position. Of course his wheelchair did not have this system so it took two or three people to get him in and out of his chair. I am surprised that 13 years later this system is not standard equipment in wheelchairs. As a previous caregiver to a person with ALS I can absolutely say that this system would be a game changer for patients and caregivers alike.

Date Submitted 2/22/2023

Susan Keldani

CMS Seat Elevation Comment    People with ALS have a very debilitating disease that drastically changes your life and then ends your life. Limits put on your body are horrible because your mind is completely fine. Anything that will help with the limitations is a huge benefit to live with dignity during the time you have left.

Date Submitted 2/22/2023

Ms. Brenda Gabrielli

CMS Seat Elevation Comment    These pts are losing all independent functioning abilities they have. Lets keep some of their dignity while they are with us!

Date Submitted 2/22/2023

Fabian A. C.

CMS Seat Elevation Comment    As an ALS patient, I ask your help us with this needs, our life is very difficult each day and having this equipment, it will improve our lives. Thank you for your support. God bless you.

Date Submitted 2/23/2023

Jennifer G.

CMS Seat Elevation Comment    ALS robs those afflicted of so much, but having ability to elevate helps them to maintain dignity and also to maintain some level of their previous independence as their disease progresses. My brother,[PHI Redacted], had an elevated chair - this improved his overall quality of life and helped reduce caregiver burdens. However, my brother also had the financial abilities to do this as he possessed a high paying job prior to his diagnosis.

If he did not have the financial ability, he would not have been able to afford the elevated chair as it was not covered.

No ALS patient should have to go without an assistive device such as an elevated wheelchair. After witnessing the horror of ALS firsthand, I implore anyone who has the power to make this decision to be aware this added benefit will greatly help all ALS warriors and their loved ones, to help keep them in their home during the battle for their life, which is exactly where they belong. If [PHI Redacted] were here still, he would beg for this to be made accessible to all ALS patients regardless of their income and/or financial status given the tremendous out of pocket expenses for other ALS care needs.

Respectfully,

Sibling of ALS warrior

Date Submitted 2/22/2023

Mark P.

CMS Seat Elevation Comment    My father in law with als could really use this and works greatly help my mother in law taking care of him

Date Submitted 2/22/2023

Molly M.

CMS Seat Elevation Comment    I was diagnosed with ALS in November 2019. I began using my power chair in 2022. I have the elevator seat. The raised seat allows me to brush my teeth, get food out of the refrigerator, open my house blinds, reach items in my pantry, get dishes out of my cupboard, heat up my food, and talk to people at eye level.

I think it is essential that ALS patients Have some semblance of normalcy which the elevated chair provides. It also allows me to be more independent while I can, meaning before my body muscles totally give out.

The elevated seat provides access to normal household features without expensive modifications, such as lowering cabinets, removing cabinet doors, etc.

I have only been awake for two hours and have used my elevated seat seven times already this morning. All of my morning activities, involved, activities of daily, living, such as taking medicine, brushing teeth, getting coffee, getting clothes from the dresser. All of this I was able to do on my own without my health care giver, which saves me quite a bit of money.

Thank you for your consideration.

Date Submitted 2/22/2023

John T.

CMS Seat Elevation Comment    Seat elevation would allow me the flexibility to continue activities such as cooking, working on my roses, or working in the garage. Thank you for considering this coverage, it would benefit so many.

Date Submitted 2/22/2023

Patrick Rafferty

CMS Seat Elevation Comment    An elevated wheelchair is part of a quality of life. When one is at standard chair level all the time one feels like a child, always having to look up to try and be part of the conversation.

Perhaps more important is the ability to change positions and take the pressure off your bottoms form sitting all the time. This can cause sores and general discomfort. Since the muscles no longer allow in to shift and stretch the ability to adjust the chair allows one to ease the pressure points.

Please, please, please improve the quality of ALS patients by having Medicare pay for seat elevated wheelchairs.

Thank you so much!

Patrick

Date Submitted 2/22/2023

Miriam K.

CMS Seat Elevation Comment    As someone who cared for my mom with ALS it was very difficult lifting her from a wheelchair in and out to bed, a vehicle, a lift-i damaged disks from the extreme difficulty and my mom would bruise from the lifting-it hurt her and ALS is a disease with no cure- why must the individual suffer the humiliation of improper lifting, movement, pain because wheelchairs do not make the task easy.

Please, whether its ALS or done other nerve disease-people are suffering when their time is so limited.

Theyve already been denied so much in treatment. This is simply about quality of the limited quantity they and we have left.

My mom Has been gone 10 years April 27th. I still get emotional thinking about the fight to protect her and how the medical system failed her.

Please approve the elevation lift for all the families currently in a fight for their lives.

Date Submitted 2/22/2023

Mrs. Cynthia T.

CMS Seat Elevation Comment    ALS is the most cruel disease known to man. There is not enough done to cure this disease. I believe because the life expectancy is so short. Numbers are not true to mankind. I believe the seat elevation on power wheelchairs is absolutely necessary and crucial to help anyone with this disease. I lost my hound mother at age 60 to this heinous disease and would do anything to have her back. I truly hope you LISTEN to HEAR those of us who advocate for these necessary items to help those suffering enormously with this devil disease.

Date Submitted 2/22/2023

Olga Jimenez

CMS Seat Elevation Comment    This is a great initiative and will improve the live of all the people with ALS

Date Submitted 2/23/2023

Thomas L.

CMS Seat Elevation Comment    With all the abilities that have eroded for my father, the ability to rise out of his wheelchair on his own is a big victory for him. This is one more way he can hold on to another small piece of his independence

Date Submitted 2/22/2023

Mr. Don Delaney

CMS Seat Elevation Comment    I was a part-time caregiver for a friend who passed away a couple of years ago. I was also a family member of a patient who passed away over 30 years ago. As far as I know, seat elevation equipment was not even available when my family member passed away, but was available for my friend's use before they passed away. So I have seen first-hand what an amazing and crucial difference this equipment can make both for the patient and for their caregivers. I fully support the effort for Medicare to cover the costs of providing this equipment.

Date Submitted 2/22/2023

Veronique Jeanmarie

CMS Seat Elevation Comment    Seat Elevation in power wheelchairs will greatly improve the quality of life for those with ALS. As ALS is a devasting disease, anything that helps with mobility issues will be a tremendous help.

Date Submitted 2/22/2023

David I.

CMS Seat Elevation Comment    power wheelchairs are not a want but a NEED. Since I paid out of pocket for elevation seat, it has improved my ability both a home and outside the home. I use it getting groceries and in almost all stores. Also in public places where I can not see, be it a person in front of me, at a concert, ball game, at cultural events and many more place. It is essential that they be allowed as standard equipment.

Date Submitted 2/22/2023

Kim Kirsch

CMS Seat Elevation Comment    This is a terrible and devastating disease. Any help offered for this population is beneficial to help them live with some dignity and meaning to life. Please help where you can.

Date Submitted 2/22/2023

Sue Vantrees

CMS Seat Elevation Comment    I have helped so many people that have ALS. When they get to the point where they can't use there legs anymore or even on there way there, the ALS patients absolutely need it. They themselves and or there caregiver need it for the extra help. So THANK YOU for doing all you can.....

Date Submitted 2/22/2023

Theresa S.

CMS Seat Elevation Comment    My boss has a son living with ALS, seat elevation in power wheelchairs is medically necessary and would improve his quality of life and his friends he has made who also have ALS.

Seat elevation in power wheelchairs does or would improve the lives of those whom give care and would make their jobs so much easier.

I lost a Grandpa several years ago with ALS and this would have made his life and the quality of his life and his caregivers as well!

Thank you for your time! ALS is an awful disease and any help that can be given would be greatly appreciated and would benefit many people!

Date Submitted 2/23/2023

Alyson Ball

CMS Seat Elevation Comment    A neighbor has ALS and seat elevation in his wheelchair is now essential for his care. Our neighbor's wife no longer has the strength to lift her husband - so seat elevation should be covered by Medicare. How can you not cover this important function in his wheelchair? Thank you.

Date Submitted 2/22/2023

Mrs. Gloria G.

CMS Seat Elevation Comment    My 30 year old daughter died of ALS. An seat elevated wheel chair would have allowed her to do more things for herself and less dependent on others.

Date Submitted 2/22/2023

Shirley Morgan

CMS Seat Elevation Comment    I have a close college girlfriend who developed ALS after working as a dental hygienist for 30 plus years. I know for a fact that seat elevation in power wheelchairs would improve her quality of life. In addition it would make her caregivers more effectively support her in her incredibly difficult journey. thank you. Shirley Morgan, RDH,QOM

Date Submitted 2/25/2023

Mrs. Nancy H.

CMS Seat Elevation Comment    My 38 year old sons March 2017 ALS diagnosis caused him to need a power wheelchair by mid 2018. He continued to work another 1.5 yrs. He had to support his family. He had been denied seat elevated coverage from his work insurance they model what Medicare covers. My son paid out of pocket for seat elevation so he could talk face to face with colleagues at social gatherings or meeting them in hallways or break rooms. He didn't feel looked down on. The same goes when he was at sporting events watching his 2 sons compete. He talked to other parents face to face. He was part of the standing group. He would go on walks with his wife-able to have eye contact in private moments. ALS Life for his family meant losing part of my son everyday. Having the elevated power wheelchair did give him increased confidence at work, spirit of comradery with sports parents & improve his limited quality of life.

Its too late for my son. After 5.5 years, he lost his ALS battle in August 2022in his memory I submit his story of LIVING with ALS to the fullest. Please approve coverage of seat elevation. It is the means to level the playing field so to speak (be at eye level) for an ALS patient trying to LIVE, WORK, & LAUGH everyday with ALS.

Respectively,

A Mom who mourns the lost of her 44 year old sons battle to live with ALS

Date Submitted 2/22/2023

Michelle B.

CMS Seat Elevation Comment    My husband had ALS and when he could no longer walk or stand , taking care of him became extremely difficult. We had to pay for his chair seat lift and it was wonderful. A caregiver needs all the equipment necessary to help them take care of their loved one at home. It can mean the difference between living at home or having to live in a nursing home. No one wants to live their final days in a nursing home. You want to be in your own home with family and friends that will spend time with you. Please allow this to happen for the patient and the caregiver. It is so very important.

Thank you

Date Submitted 2/22/2023

Larry A.

CMS Seat Elevation Comment    When my wife was diagnosed with ALS, we were devastated. Our lives were changing despite all of our careful planning. She eventually lost the use of her legs and we moved her to a medical bed in what used to be our breakfast room. The power wheelchair allowed her some limited freedom and control but getting her into and out of the wheelchair from the bed proved challenging. I was unable to physically lift her and no one else was available to assist me in the transfer. We struggled to make the transfer as she was also physically weak in her arms. Having the bed and the wheelchair at the same height would have been a great help as I could have slid her from one to the other using a sheet. As it was, it quickly became too difficult to perform this operation and she resigned herself to just living out her life in bed. So sad for us both to see your loved one dying a slow death and not being able to do anything about it.

Date Submitted 2/27/2023

Trish Trull

CMS Seat Elevation Comment    My friend recently passed away with ALS. It was heartbreaking to watch the struggles her husband had in caring for her. The seat elevation equipment for a power wheelchair would have helped tremendously with her care. They struggled financially because of the medical costs that was not covered by any insurances. This proposal would benefit the ALS Community greatly.

Date Submitted 2/24/2023

Beth Chlopek

CMS Seat Elevation Comment    To be able to elevate the seat on a powered wheelchair allows access to be able to get into a car without having to have necessarily a special vehicle to accommodate the wheelchair becoming the seat for us and would also help any disabled person with difficulty getting into a car be able to travel to and from doctors with less or no difficulty. So please allow us to be able to go places easier and have that small perk be a blessing in a time of extremely challenging circumstances, Beth Chlopek

Date Submitted 2/22/2023

Kevis C.

CMS Seat Elevation Comment    I AM NOW 51 YEAR OLD AFRICAN AMERICAN; WHO WAS EMPLOYED AND MAKING $100,000+ INCOME A YEAR AS AN IT PROFESSIONAL. I HAD OVER 25 YEARS OF EXPERIENCE IN BUSINESS AND MANAGEMENT BEFORE MY MEDICAL INJURY; AS A RESULT OF DR CHARLES HUBBARDS' NEGLIGENCE. IT TOOK ME 4 YEARS TO IDENTIFY THE SOURCE OF MY MEDICAL CONDITION BY VISITING SEVERAL MEDICAL SPECIALISTS AT THE MAYO CLINIC(ROCHESTER, MN); DR BRIAN STRAUSS (ORTHOPEDIC SURGEON/FORMER MAVERICKS TEAM DOCTOR - DALLAS, TX) DR JEFFEREY ELLIOTT - CHIEF NEUROLOGIST UT SOUTHWESTERN MEDICAL CENTER - DALLAS. TX. I WAS DIAGNOSED IN 2009 WITH AUTOIMMUNE ALS.

MY DOCTORS, FOUND THAT DUE TO THE BONE GRAFT USED BY DR HUBBARD DURING MY SURGERY CAUSED A VIRAL INFECTION IN MY BLOOD AND BODY; SINCE DR HUBBARD FAILED TO PRESCRIBED ANTI-REJECTION DRUGS. WHEN I NOTIFIED DR HUBBARD OF MY ISSUES DURING POST-OP VISITS FOR MY ANKLE SURGERY HE PERFORMED; HE WOULD SAY I HAVE SLIGHT ARTHRITIS TO EXPLAIN THE STIFFNESS IN MY BODY; OR ALLERGIES TO EXPLAIN MY SUDDEN SLURRED SPEECH, I DID NOT BELIEVE HIM AND BEGAN TO SEEK OUT MORE SPECIALIZED CARE TO UNDERSTAND THE CHANGES IN MY BODY.

DUE TO THE TORT LAW REGARDING MEDICAL MALPRACTICE THERE IS NO PROVISION FOR ADEQUATE TIME FRAMES FOR DISCOVERY SO A COMPLAINT CAN PROVIDE THE BURDEN OF PROOF WHEN A MEDICAL INJURY OCCURS; WHICH IS MY CASE. LAWYERS, I SOUGHT COUNSEL FROM; DID NOT WANT TO TAKE MY CASE OR EVEN TRY BECAUSE OF THE MALPRACTICE LAWS IN TEXAS. MY RIGHTS TO FAIR LEGAL REPRESENTATION WAS DENIED. I FEEL MORE ACCOUNTABILITY NEEDS TO BE AFFORDED FOR TEXANS BEING SUBJECTED TO CARELESS AND NEGLIGENT MEDICAL PROFESSIONALS.

DUE TO MY WORSENING HEALTH; I CAN NO LONGER OBTAIN GAINFUL EMPLOYMENT; BEFORE MY MEDICAL INJURY AND NOW AM ON DISABILITY AND A UNCERTAIN FUTURE REGARDING MY MEDICAL CONDITION AS IT HAS WORSEN.

Date Submitted 2/22/2023

Frank Z.

CMS Seat Elevation Comment    I have had ALS for more than 11yrs. which is unusual. I think of many circumstances over that time and now when a motor on my chair to control the height would have been and can be a godsend. I highly recommend that you pass legislation in favor of Medicare funding the motors to lift and lower wheelchair seats for ALS patients.

Date Submitted 2/24/2023

Linda C. H.

CMS Seat Elevation Comment    Seat elevation would mean we could stop adding uncomfortable cushions that fall off and would make me so much more independent and not ask for help to stand!! YES PLEASE!!! It would help caregivers so much to not have to lift ALS victims/patients!!!!

Date Submitted 2/22/2023

Megan Ryno

CMS Seat Elevation Comment    As a caregiver for a person with ALS, I can confidently state that seat elevation in power wheelchairs improves the quality of life for the person with ALS by allowing them to sit in a more comfortable position. Being in a more comfortable position allows them to better interact with the world, and be more present with their family and friends. It prevents strain on a body that is already strained in so many other ways.

As a caregiver, seat elevation also brings me comfort, because I know my person with ALS is as comfortable as they can be for the moment, and are not in a position to be injured.

Date Submitted 2/22/2023

Lizbeth D.

CMS Seat Elevation Comment    My husband is not in a wheelchair yet, but I can only imagine that a lift in a wheelchair would not only be about living with dignity, but also the ease of moving from the chair to the bed, or the car etc. It would be a blessing to both the patient & the caregivers.

Date Submitted 2/23/2023

Elizabeth Baker

CMS Seat Elevation Comment    Why would make life even harder for those living with ALS? Seat elevation wheelchairs and similar devices often allow for patient to have a little more independence for longer and also assists with keeping caregivers safe. This is something very small they can improve the quality of someone's life.

Date Submitted 2/22/2023

Mr. John Lautzenhiser

CMS Seat Elevation Comment    Individuals need and benefit from all the support that can be made available to them. Just apply the golden rule and know the right thing to do. John Lautzenhiser

Date Submitted 2/22/2023

Barbara C.

CMS Seat Elevation Comment    My brother-in-law died from ALS. Life would have been easier for him with the seat elevation seat for power wheelchairs.

Date Submitted 2/22/2023

Ashley Loyning

CMS Seat Elevation Comment    I'm a Speech-Language Pathologist currently practicing at the ALS Association and urge Medicare to recognize the value in covering seat elevation for people living with ALS (pALS) and other conditions. Seat elevation allows pALS to access their environment with reduced barriers and enables them to participate in medical and social activities with increased independence. Increased independence results in decreased dependence on caregivers and reduces caregiver burden and burnout. Due to the typical rapid progression of ALS, it is crucial that Medicare cover seat elevation and expedite the process for pALS to ensure they can participate as independently and as long as possible.

Thank you,

Ashley Loyning, M.S., CCC-SLP

Date Submitted 2/23/2023

Ms. Kristy Allen

CMS Seat Elevation Comment    I am a physical therapist who has specialized in treating patients with ALS for the past 18 years. The majority of pALS will require a power wheelchair for mobility at some point in the progression of their disease. A seat elevator is a vital part of that power wheelchair to allow people to reach items such as light switches, access counter tops, faucets, stove tops etc. It is needed to allow people who require a wheelchair to be independent with the daily activities and interact within their environment. the seat elevator also allows patients to be independent longer with transfers from their chair. The elevated seat height requires less LE strength and balance allowing them to safely transfer to a toilet/commode or their bed. For people who require family members to assist them with transfers, being able to elevate the chair significantly improves the safety and difficulty with assisted transfers as well. Without the seat elevator most patients will require a Hoyer Lift which is an additional cost.

There is also the social and mental aspect of a power seat elevator. It allows the person to interact with family members, medical personal and friends at the same eye level. It can not be overstated how important this is for someone's mental health.

As a practitioner who specializes in ALS patient care and also wheelchair clinics I have never understood how a power seat elevator was not a covered item. There are few things that would improve a person's quality of life when in a power wheelchair more than a seat elevator.

Date Submitted 2/22/2023

Rev Dr William C H.

CMS Seat Elevation Comment    hi, i have had ALS for 15 years and always paid the out-of-pocket cost for the elevated seat lift. although it put additional burden on my budget, it is absolutely necessary for my quality of life. it is needed for reaching items above me, necessary for transferring me to my bed without a major lifting struggle and needed for my tube feeding for nourishment. please support this addition for all the other people who are confined to a wheelchair. thank you.

Date Submitted 2/22/2023

Mr. Steven R.

CMS Seat Elevation Comment    My father suffered from ALS and it was a painful experience for both my father and our family. This cruel disease eventually took his life. It was a horrific tragedy of the mental and financial stress that it put on my father and our family. Resources were hard to find, so every new addition to services is a great relief to both patients and families.

Date Submitted 2/22/2023

MIchael L.

CMS Seat Elevation Comment    Elevated wheelchair seat will help me be able to reach some kitchen cabinets and shelves in refrigerator, get in and out of bed easier, on and off toilet. Also will be able to get up to the table to eat meals. It will make it easier for my wife to help. I was diagnosed limb onset Oct 2018.

Date Submitted 2/22/2023

Mark R.

CMS Seat Elevation Comment    Observing life from down below is yet another slap in the face with this disease. Not being able to look out windows, straining your eyes trying to see the faces of other people you're with because your neck is weak and your head sags, and having to do all your grooming in a mirror sitting on the floor. These are just a few of the negative impacts a standing chair could eliminate. It's just one dignity after another stripped away from us with this disease. It would be nice to feel my government is willing to enhance my life. Thank you for considering this life changing option for every one of us living in a wheelchair because of diseases and accidents we didn't choose.

Date Submitted 2/22/2023

Mrs. Jamie Schwartz

CMS Seat Elevation Comment    This is so important for ALS patients quality of life and function.

Date Submitted 2/22/2023

Ms. Johnette Davies

CMS Seat Elevation Comment    The ability to use seat elevation technology helps prolong the autonomy of ALS patients and provides a better quality of life. It is crucial for caregivers. Lifting someone from a seated position can be challenging, if not impossible depending on the circumstance. Seat elevation technology assists caregivers, who may have their own health issues and not be able to lift the patient without causing harm to themselves.

Date Submitted 2/26/2023

Kimberly B.

CMS Seat Elevation Comment    Power wheelchairs for ALS patients are not a luxury but a necessity. It can improve their quality of life and provide them with some ability to have freedom or independence from a caregiver. My brother battled ALS for 3.5 years. I find it sad on the way Medicare treats people with this disease that is 100% fatal. I would hope Medicare decision makers would take the time to meet with patients with ALS to better understand how they can help vs. trying to save a $ to make a budget. Quality of Life (QOL) is critical for these patients and none of them should be "fighting" with Medicare to be granted a wheelchair and/or features in a wheelchair that can help their QOL. They should be spending their time shortened life spans living and making memories with their families vs. fighting with Medicare. Best- Kim B. (Sister of Rob B. who fought ALS for 3.5 years before passing in March 12, 2021)

Date Submitted 2/24/2023

David M.

CMS Seat Elevation Comment    The ALS story is not pretty.

Having a wheelchair with a riser seat chair is our gift. It so much makes our life easier as we go through our challenging days. We would sure appreciate it if we could get some assistance. I feel it is not only ALS patients/caregivers but many patients of various diseases that would be impacted.

Please would you consider assistance to people who need to have a "lift" in their lives.

Thank you

JoAnn

Date Submitted 2/22/2023

Corinne D.

CMS Seat Elevation Comment    My brother has ALS and this will allow him to be able to see the world even when he gets to the latter stages of his disease please approve this in order to provide a better quality of life for all patients that have ALS

Date Submitted 2/23/2023

Jared Kerns

CMS Seat Elevation Comment    Being in the DME industry I have seen many patients whose lives would significantly improve with the coverage of power seat elevate. I have seen this simple addition give patients independence by allowing them to operate their microwaves allowing them to prepare food for themselves.

Date Submitted 2/22/2023

Don W.

CMS Seat Elevation Comment    The seat elevator has allowed me the ability to reach countertops to brush my teeth, reach tables at the proper height, to look people at eye level when having a conversation, reach the sign in desks for doctors visits, to raise to the same level as others at church when we are singing and so much more!! It also helps me get up the wheelchair ramp which requires your feet to be raised and look out our patio windows so I can enjoy the view. All of this to say, it has made my quality of life so much better and would want that to be available for all who need it, especially ALS patients with such a short life span upon diagnosis!!!

Date Submitted 2/22/2023

Patty Bradshaw

CMS Seat Elevation Comment    I was a caregiver for a beautiful woman with ALS for about 3 1/2 years. This disease is wretched. Seat elevation is one way to make their lives a little less miserable. Please give all you can to help people with ALS and their families cope with this (so far) incurable disease.

Date Submitted 2/23/2023

Denise W.

CMS Seat Elevation Comment    A seat elevator on a power chair greatly improves the quality of life for someone living with ALS. Our Mom benefitted greatly by having the ability to speak to people at eye level, and reach items where she needed too. This also benefitted me as her caregiver to focus on other things needing to be done leaving Mom independent a little longer. Remember, ALS strips the individual from living a independent and normal life. We should not have to apply for grants to get what our loved ones NEED. Thank you!!

Date Submitted 2/22/2023

Amanda Pieters

CMS Seat Elevation Comment    Supporting a dear friend with an ALS diagnosis, I learned quickly that little things can add up to big impacts, especially in everyday life. Seat elevation in power wheelchairs is a simple, and powerful, way to help maintain a person's integrity and quality of life while living with an incurable disease. It is also a wonderful way to help improve the life of caregivers.

The physical limitations, and sometimes rapid symptom changes, that come with ALS require caregivers and people living with ALS the need to have options available to them in a short amount of time. Having Medicare cover costs of seat elevation equipment for power wheelchairs is a tangible way to remove a barrier for individuals to access equipment they need that they may not have needed the week before. This helps caregivers access items more quickly and affordably, in turn helping a person living with ALS live more comfortably and independently than before.

Life is precious. Time together with loved ones is precious. And those living with ALS cannot say with certainly how long they will live with the disease. Medicare coverage of seat elevation in power wheelchairs is important to me, because I wish my friend could have felt more fresh air, had more conversations "eye to eye" and had the opportunity to demonstrate the autonomy they had in that moment to function how they wanted, when they wanted. And seat elevation could have provided that. Please, please help to remove additional financial strain, emotional stress, and barriers for caregivers and people living with ALS. Approve the Medicare coverage of seat elevation equipment for power wheelchairs. Thank you.

Date Submitted 2/23/2023

Wave Waiting Period For Als Patients Marlene S.

CMS Seat Elevation Comment    My husband had ALS for 7 years.

We took care of him all that time. He was 63 and weighted 211.

I know from experience how much that would help making a patient comfortable and also help prevent bed sores.

It would be a great help for the caregiver.

Date Submitted 2/23/2023

Mr. Thomas Farrell

CMS Seat Elevation Comment    It is about time, the VA has allowed this for years!!!!!!!!!!!!

Date Submitted 2/23/2023

Myron Behrendt

CMS Seat Elevation Comment    ALS patients need whatever is possible to help them through.

Date Submitted 2/22/2023

 Johnna R.

CMS Seat Elevation Comment    I am a former caregiver for my husband, who passed away from ALS in 2003. After 20 years, some things that are helpful to the patient, as well as the family are finally coming to fruition.

I feel any medical durable device for ALS patients that provides varying amounts of vertical seat to floor height is a good thing. It does not change the seated angles or the seat's angle relative to the ground, but will offer a means to provide more mobility for the patient.

As far as my experience goes, anything that can help prolong, and enable more mobility during the duration of this horrific disease, gets a thumbs up from me.

Sincerely,

Date Submitted 2/22/2023

Henry E.

CMS Seat Elevation Comment    The absurdity of a 98 lb woman trying to maneuver a 170 lb patient, who totally paralyzed, from a hospital bed to a wheelchair, and back again is beyond comprehension! This is the saga of my son, who, at the age of 48, was diagnosed with ALS, with no history of this disease in his ancestry.

Date Submitted 2/22/2023

John S.

CMS Seat Elevation Comment    I wish we had this when my wife was alive! I was her caregiver and certainly would have helped her! Thank you for Your support!

Date Submitted 2/22/2023

Judy Salkovitz

CMS Seat Elevation Comment    Our family LOST three people to ALS [a father + 2 sons] & this was before the 'ice bucket' wager that alerted the entire USA to a devastating disease. ANY product that can assist an ALS patient (along w/their caretakers) can only be a blessing...and should not be a 'consideration'. Thank you, Judy Salkovitz, Haverhill MA

Date Submitted 2/23/2023

Mrs. Teri C.

CMS Seat Elevation Comment    Please fund ALS for anything that would make a person more comfortable. My father passed away in 2016 from this awful disease. In memory of my father Richard B C.

Date Submitted 2/22/2023

Gerri Lynn Zschetzsche

CMS Seat Elevation Comment    It is so difficult to lose your ability to get around for ALS patients. Anything that can help them with mobility is a huge plus and improves their quality of life.

Date Submitted 2/22/2023

William B.

CMS Seat Elevation Comment    I have ALS and use a power wheelchair. I use seat elevation to help me stand and transfer. It's very important.

Date Submitted 2/22/2023

Mary R.

CMS Seat Elevation Comment    I have great difficulty when trying to cook my meals it is hard to reach the stove also pantry items and as a result I am losing weight. The elevation would really help me prepare my meals much easier. Thank You!

Date Submitted 2/22/2023

Mr. Michael A.

CMS Seat Elevation Comment    Seat elevation is essential to me and my caregivers. I am able to stand to accomplish transfers by elevating the seat and pulling up with a grab bar. Additionally the seat elevation allows me to remove things from cabinets I could not normally reach without seat elevation. I am able to wash my hands, brush my teeth and shave over a sink with seat elevation.

Seat elevation makes it so much easier to assist with changing my clothes. I am able to elevate the seat thereby reducing their having to bend over to assist with clothing me or sit on the floor to put my shoes on.

The seat elevation is a must have for both ALS patients and caregivers!

Date Submitted 2/22/2023

Bev G.

CMS Seat Elevation Comment    My husband was diagnosed with ALS September of 2019 and passed away January 2020.

He never needed the chair, however Minnesota is fabulous and supplying the patient with all needs of an ALS patients.

The chair lift is needed by the caretaker, and especially the patient.

Date Submitted 2/22/2023

Lucyna D.

CMS Seat Elevation Comment    My husband died of ALS in 2020. In addition to dealing with the illness in the middle of pandemic, our family dealt with costs of horrendous medical devices costs. Seat elevation is medically necessary for a person with ALS. Please just visit someone who is sick of ALS.

Date Submitted 2/23/2023

Ms. Char P.

CMS Seat Elevation Comment    ALS is genetic in my family. There is a 50% chance that myself, my siblings, and many of my cousins will pass away before age 55 from this disease. My mother developed ALS at the age of 38, just when her life was beginning. She was the first of her siblings to get ALS, but not the last. I was only 8 but one of my responsibilities when she was sick was to assist her in moving from her chair to the toilet. I still remember the day that she lost the ability to lift herself from the toilet to stand. I remember the tears, the screaming, the panic attack she had at realizing just how fast her disease was progressing. We had to spend our own money purchasing a new toilet that was taller because we didnt have access to assistance devices like a power chair with elevation to move her. It eventually became my dads job to help her use the bathroom as I wasn't strong enough to lift her. Supporting the decision to include elevation devices on power chairs with Medicare means less trauma, less panic attacks, less pain, less tears, and less stress for ALS patients who are desperate to maintain even an ounce of independence.

Date Submitted 2/22/2023

Ms. Terri S.

CMS Seat Elevation Comment    My husband lost his battle with ALS on 10/7/10.

It was an extremely painful journey seeing him slowly disappear losing all function.

He was a brilliant man, commercial airline captain, and a loving husband, father, grandfather, and friend.

Any help, for those that fight this disease, should be given as once diagnosed it is a death sentence. The end of life caused by not being able to breathe, swallow, speak,etc.

In my husbands case the disease quickly traveled to his brain, taking him away from us mentally.

Many other diseases have medications etc. That offer a chance to live.

ALS DOES NOT.

I was grateful for the support of the ALS Association during his illness. They offered support for patient and family.

Date Submitted 2/24/2023

Laurene Walker

CMS Seat Elevation Comment    By enacting this procedure for ALS folks, it will make their life easier.

Date Submitted 2/23/2023

Ms. Mary L.

CMS Seat Elevation Comment    This is a very disabling disease that is very expensive even when covered by insurance. And as insurance companies change their payouts the economic struggles of ALS patients becomes even more difficult and challenging. Income care, assisted living, and nursing home care runs between 5 and 10,000 a month and most of us don't have that. Please allow us to be as independent for as long as we can by covering the lift in wheelchairs so that we can continue to try and care for ourselves and void huge debt that cannot be covered by those with ALS. Home alterations can provide some aid but it's very limited and of course very costly. Please give us quality of life.

Date Submitted 2/24/2023

Mrs. Candy K.

CMS Seat Elevation Comment    My husband recently passed from ALS after a diagnosis 20 years ago. the seat elevator was so useful to reposition him so he could get food from a buffet, sit at a table, get into a wheelchair van without bumping his head, make it easier for caregivers to care for him, give him independence, which he lost mostly in these last few years. it is important to get this feature early in the disease progression.

Date Submitted 2/23/2023

Deborah Z.

CMS Seat Elevation Comment    When my dad had ALS over 20 years ago, in order to get him out of his chair or a wheelchair, we had to wrap our arm around him under his armpits and help him up. It was not easy for any of us. A chair lift would have been a godsend to save our backs.

Date Submitted 2/22/2023

Ms. Pat Poulos

CMS Seat Elevation Comment    Definitely needed

Date Submitted 2/22/2023

Adam M.

CMS Seat Elevation Comment    My father could not have left the house without seat elevation equipment in our van. This is so important for the quality of life for both the patient and the caregivers. Please make this coverage available!

Thank you

Date Submitted 2/23/2023

Anne M.

CMS Seat Elevation Comment    My husband, recently retired Anesthesiologist, had ALS , diagnosed 6/23/20 & passed away 8/1821. He was completely paralyzed from the neck down by 10/1/20. Without the elevated seat, it would have been next to impossible to transfer him. As it was it took 3 people to transfer him for bathroom, bathing & feeding needs. A horrific disease.

Date Submitted 2/22/2023

Sarah Turner

CMS Seat Elevation Comment    Seat elevation for ALS patients is very important. It adds quality of life by allowing the patient to converse, eye-to-eye, with friends, family, caregivers and medical providers. It returns dignity to the patient when they no longer need to have others awkwardly bend down to speak in social and medical settings. It also helps caregivers with physical limitations by relieving them of the necessity to bend down to interact with the patient.

Date Submitted 2/22/2023

Mrs. Ellen Masters Massa

CMS Seat Elevation Comment    Living with and taking care of a person living with ALS is a monumental task, even when that care is given with love. When the time comes that a power wheelchair is needed, it is imperative that one of the features be seat elevation. Being able to raise the seat is important in several ways. For starters, it allows the individual the freedom to reach for something that is slightly higher, like the shirt or book from a shelf. It also allows a person to SAFELY navigate the crowds on a sidewalk or a large gathering of people more easily. People don't always see a wheelchair or the person in the chair. Folks can be totally unaware of their surroundings, espcially if they are in a hurry or looking too far ahead. They literally don't see what's in front or along side of them, especially if the person or object is below their line of site. Raising the seat not only makes the individual more visible, but that person is better able to see what is ahead of him/her as well, especially in a crowded place. The seat elevation feature also allows the individual to feel a part of a conversation, be it with a group or with another individual. It's essential to make eye contact and to be able to hear what someone is saying, and just as importantly, have them hear you. Power wheelchairs and seat elevation ultimately allow someone living with ALS to extend their independence and most importantly, remain safe.

Date Submitted 2/22/2023

Gilbert Perez

CMS Seat Elevation Comment    Anything that gives more access is a big help

Date Submitted 2/24/2023

William M.

CMS Seat Elevation Comment    My wife Laurena lived with ALS for 3 years. Watching this disease take away everything piece by piece that made life worth living was the hardest thing ill ever have to endure. Laurenas only freedom was her ability to navigate her wheelchair. It was her only comfort. Anything we can do for these poor souls suffering is our responsibility as humans. Any less is inhumane. Please dont put limits on providing compassionate care. This could easily be you or a family member. Trust me i know

Date Submitted 2/22/2023

Terry V.

CMS Seat Elevation Comment    A elevated power w/c would help improve my husbands ability to sit at the kitchen counter to have his meals and to get closer to the bathroom sink for his toiletries. It will help him reach things without asking for help. He needs to feel as much independence as possible because those days will soon disappear.

Date Submitted 2/22/2023

Rebecca Aspengren

CMS Seat Elevation Comment    I recently lost my dear friend from FYD...I wayched while she and her family suffered every day..any added help that these patients receive will be a godsend in a very difficult world..It is the right thing to do..thank you

Date Submitted 2/22/2023

Ms. Alexandra Pierzynski

CMS Seat Elevation Comment    Seat elevation in power wheelchairs would help people living with ALS to complete activities of daily living. This is essential to their ever day care and would make a difference in the lives of those living with ALS and their caregivers.

Date Submitted 2/22/2023

Olivia Fite

CMS Seat Elevation Comment    This is the very least you can do. Please support covering the cost of seat elevation equipment for power wheelchairs. This is an important step in supporting our beloveds who have ALS and their caregivers.

Date Submitted 2/24/2023

Melissa E.

CMS Seat Elevation Comment    I am person living with a condition that has me using a power wheelchair. I am so thankful for the seat elevation system. It has improved my quality of life. It has made it easier to continue functioning independently. I am able to reach things that are high. I am able to elevate to see over obstacles that are in my way. It allows me tosee eye to eye with others when having conversations.

My wife is my caregiver and it has made a huge difference for her. I am able to raise the seat for her to feed me and give medicine through my feeding tube. I am also able to elevate to get in and out of the seat with her assistance. This has kept her from hurting herself while doing these task necessary for my healthcare.

Having the elevating seat on my power chair is important to me because has made a huge difference in my quality of life and provided me more independence. It has also been important and necessary to keep

my caregiver safe and make it easier for her to give a better quality of care to me.

Date Submitted 2/25/2023

Mr. Vincent C.

CMS Seat Elevation Comment    This is a much needed thing to us who eat from different heights and easier to see something as easy for most people to watch television. Lots of us can not raise head and hold upright for long periods. and it gives more Independence to at least brush teeth and maybe shave. Thank you for your time and efforts in this.

Date Submitted 2/22/2023

Katharine S.

CMS Seat Elevation Comment    My brother Tucker S. lived an incredibly productive and vibrant life for 17 years with ALS. His power wheelchair made all the difference to him and to our family and friends who all helped care for him. It was so important to him personally that it was even his artistic muse many, many times.

To not give ALS patients access to the best, most versatile assistive technology possible is downright CRUEL.

Date Submitted 2/22/2023

Mrs. Sharon Barney-Casey

CMS Seat Elevation Comment    Its just a matter of common sense. If someone is losing muscle control anything that can help them get into and out of a wheelchair is a no brainer.

Date Submitted 2/24/2023

Ms. Polly Anna R.

CMS Seat Elevation Comment    My husband died from ALS in 2008 but I have clear memories of how essential his wheelchair elevation was. It was the one essential feature not covered by Medicare. Thankfully a donation from another source paid for it but not everyone is fortunate enough to have other payment options. The lift feature helped when I had to transfer him from the wheelchair to the bed or to a recliner, helped position him to be able to eat successfully, helped when I or aides had to exercise his limbs, helped position him for daily bathing and dental care. So, so many daily needs were made possible by having that lift feature. I sincerely hope Medicare will cover this feature for those suffering from ALS and for the caregivers tasked to care for them.

Date Submitted 2/23/2023

Carlos M.

CMS Seat Elevation Comment    I'm a caregiver for my wife and we both see seat elevation is a key mechanism for continued accessibility. There are several smaller tasks, such as cooking or preparing, that are not feasible at the usual wheelchair height. In fact, cooking is not safe if the seat is not elevated. As ALS progress, patient will have limitation on raising arms and seat elevation can keep them independent on sinks and low cabinets, such as bathroom ones. Seat elevation can also provide an adequate height for transferring the patient to a bed, making it easier to adapt the home to the patient. The longer the patient can keep independence, the more dignity can be preserved. The longer the patient is independent, the easier for caregivers, who can keep working and paying medicare/insurance.

Date Submitted 2/22/2023

Rohit Kumar

CMS Seat Elevation Comment    Seat elevation is critical to proper caregiving and comfort of patients.

Date Submitted 2/22/2023

Charles P.

CMS Seat Elevation Comment    I know how hard it is for patient & care giver for a family dealing with ALS. I lost my wife nov. 26. 2012 to ALS.after 48 years of marriage. I know any thing that would help would be a blessing for these family's.

Date Submitted 2/22/2023

Rebecca Taylor-Negus

CMS Seat Elevation Comment    My best friend's mother was diagnosed with ALS. It was heartbreaking to see her deterioration over what seemed to be a very short time. Anything that can be done to help and comfort those individuals to manage this terrible disease is extremely important.

Date Submitted 2/22/2023

Terry Baumgardner

CMS Seat Elevation Comment    We need to do all we can to those with ALS and seat elevation would definitely be a huge help to them and especially to their caregivers.

Date Submitted 2/22/2023

Stacy C.

CMS Seat Elevation Comment    My father in law and husband both died from ALS. My mother in law took care of my father in law until the end in there home. She struggled to lift a man that was 62 and 200 pounds to get him into a wheelchair. It took a toll on her. My husband died January 29, 2016. I to took care of my husband until the end. He died at home. We tried repeatedly to get help to get him a power wheelchair and a lift bed. He used a walker to get to the bathroom and come back. At the end his legs were giving out and we bought him a portable urinal. We struggled to get him to the toilet for a BM. No one realized the pain these people go through. Having to give up there independence, and having to rely on others. Things you take for granted. The chair would at least give them the capability to move around more. Go outside instead of looking out a window. For fear they will fall. My husband at the end told me thats what he missed the most was his independence. He was to the point of not wanted to live anymore. I had to get rid of the Huns in the house for fear he would take his own life. The chair would have given him some of that back.

Date Submitted 2/22/2023

Lisa G.

CMS Seat Elevation Comment    Seat elevation is a game changer for anyone that is in a power wheelchair. It gives us greater independence in the ability to perform everyday tasks. Imagine being able to reach into a cabinet without having to ask for assistance. Better yet, how about being able to safely cook on the stove.

Transfers can be made safely when moving from the bed into the chair. Being able to reach clothes easily in the closet is another asset. All of these things also give our caregivers a break.

It's time seat elevation be considered as a basic need for anyone that is in a wheelchair. It allows me to retain my independence and dignity in my everyday tasks.

Date Submitted 2/22/2023

Mary C.

CMS Seat Elevation Comment    I am an ALS patient on Medicare with both lower and upper extremity weakness that continues to increase. Getting out of a seated position from chairs, scooters etc. is extremely difficult if my hips are not above my knees. Unfortunately, a power wheelchair is in my near future and having the seat elevation option will be paramount to my being able to access and exit the wheelchair as well as to my safety and the safety of my caregiver while doing so. Thank you for your consideration.

Date Submitted 2/22/2023

Scott Christensen

CMS Seat Elevation Comment    Lisa was a beautiful, vibrant healthy, active middle aged woman. She started noticing weakness when trying to stand from a squatted position. Difficulty jumping, pain in her back and left leg..after back surgery and rehabilitation making it even worse. She was diagnosed with ALS . June 12, 2019. The devastating news was met with a powerful positive attitude and no fear of the what would come next!! Death was her only out from the pain of becoming paralyzed a little at a time until she was unable to breathe because her diaphragm muscles no longer responded to the nerve signals to keep her filled with oxygen. Death in 2 years and 9 days from diagnosis to death

She left behind a beautiful family. Her loving and devoted husband of 30 years, 2 children 4 grandchildren.

The financial costs of this disease can be assisted and the burden lightened by the decision YOU make to aid with cost such as height assessment. To have a motorized wheelchair that brings it's bearer to a comfortable level to communicate with others and feel included in their own life.

Be kind and compassionate and help these amazing families deal with this devastation as much wife did with class grace and style far beyond the bounds of this physical sphere.

Date Submitted 2/22/2023

Michael D.

CMS Seat Elevation Comment    My wife has ALS - having seat elevation is critical to her ability to remain mobile and do things for herself. It helps her sense of independence and her mental health tremendously!

Date Submitted 2/22/2023

Diane S.

CMS Seat Elevation Comment    My husband had a wheelchair that allowed him to stand once being properly strapped in. He loved it to let the blood flow throughout his body and give pressure points relief. He was able to drive it around standing up, first one around in our area. Heads were spinning when people saw him

Date Submitted 2/22/2023

Mrs. Lisa H.

CMS Seat Elevation Comment    I support the ALS Association and support this Medicare proposal. My mother-in-law died of ALS over 10 years ago. Each time there is an improvement in research, medication, support for anyone suffering with ALS, I am very thankful. L.

Date Submitted 2/24/2023

Dennis Del Grosso

CMS Seat Elevation Comment    If you doubt how necessary these are, simply try getting out of a chair WITHOUT using your hands, arms, or legs. Can't be done! Then try having your spouse or partner help. Unless they are a serious weight lifter, they will struggle mightily, IF they can dead-lift you at all. Now you will understand.

Date Submitted 2/22/2023

Mrs. Marguerite M.

CMS Seat Elevation Comment    My late husband had ALS. At the age of 47, he quickly became completely paralyzed and dependent on his power wheelchair. We were fortunate enough to have the support of the VA. We received a chair with both tilt and seat elevation. The tilt feature is not an option with ALS. In the case of my husband, it was necessary for his ease in breathing. The seat elevation allowed him to speak to people at eye level. It saved my back when I was shaving him. Before complete paralysis, the seat elevation aided in transfers. This coverage by Medicare is important to me because I know how much seat elevation improved our very difficult life. After my husband's death, I returned to school and earned a Master's degree in Social Work so that I could work with ALS patients. It breaks my heart to see a family have to suffer because the correct equipment is denied by Medicare.

Date Submitted 2/22/2023

Mark A.

CMS Seat Elevation Comment    I am a caregiver for my wife, who has ALS. Having the elevate feature has been so helpful to all of our lives. It allows much easier transfers, allows being able to reach things higher than without. It opens up seating selection at restaurants, as a lot of restaurants have very limited accessible seats. It also helps when interacting with people, as the user can elevate to roughly eye level and not have to be looked down to all the time. We can not imagine living without this feature.

Date Submitted 2/22/2023

Mark W.

CMS Seat Elevation Comment    My Mother died from complications of ALS and I took her to the Dr. and support group meetings, so Ive seen many people struggle with physical maneuvering in traditional chairs. Lifts would greatly increase safety, comfort and agility.

Date Submitted 2/22/2023

Jourdan Milliard

CMS Seat Elevation Comment    My patients progressively lose their independence as their disease advances. They have to rely on others for simple tasks of feeding and bathing. Having a seat elevator gives them the ability to have one aspect of independence whether it's to reach up to a cabinet or transfer safely to a toilet. Seat elevators are a necessary feature to their chairs and most patients with ALS spend the majority of their time living in these mobility devices. I can't even imagine how it would feel to be stripped of your function and independence. You have the ability to help improve their quality of life with this decision.

Date Submitted 2/22/2023

Ana A.

CMS Seat Elevation Comment    I am a person living with ALS and I need a power wheelchair. but I don't have the necessary money to pay the co-payment, which is 4,500 dollars, for me at this moment it is impossible to make that payment and I really need the chair to have greater mobility and a better quality of life since I cannot leave the house without help and my legs are not working well, I have suffered multiple falls

Date Submitted 2/28/2023

Heather A.

CMS Seat Elevation Comment    My brother in law has ALS and has been wheelchair confined for several yesrs. He is 6 foot 4. My sister, his primary caregiver, is 5 foot 2. Seat elevation would assist her in caring for him and him in adjusting himself. My sister strained her back caring for Marc and had to have physical therapy. That means finding and paying someone to care for him while she is out for treatment. Life with ALS is incredibly difficult for patients and families as the afflicted can not do much for themselves. Every possible thing that can assist provides the patient with some amount of independence and a little respite for caregivers. Please don't underestimate the importance of seat elevation and pass this rule. Thank you.

Date Submitted 2/23/2023

Ms. Sara Hoten

CMS Seat Elevation Comment    People w/ALS NEED seat elevators for their power wheelchairs. Having this covered by insurance would be a game changer for so many individuals and reduce a huge financial burden for families and organizations that are assisting these families. Seat elevators are a necessity for people with ALS and reduce the risk during transfers for the individual AND their caregiver, (among other things). Please provide this coverage for the individuals I work with on a daily basis.

Date Submitted 2/23/2023

Joanne G.

CMS Seat Elevation Comment    My brother died of his ALS 5/22/22, I was all he had. I was his caregiver, & trustee, so I am still dealing with the estate as trustee & all of the work involved to provide info. to the attorneys paralegal to complete forms for estate closure. Thank God for the ALS Assn., they take care of those afflicted & their families after your loved one has passed. But nowadays so many people are diagnosed with this deadly disease that the government/ Medicare must do more in paying for necessary equipment to help the afflicted & the caregivers. The entire process from diagnosis to death is a nightmare for the afflicted & caretakers, relatives. It is the worst disease I have witnessed anyone succumbing from. The average lifespan from diagnosis to death is 3 1/2 yrs. The cost of equipment, care, caretakers is prohibitive, along with the emotional component ongoing & the aftermath. With all of the taxes paid & wasted by the govt. in this country can we please use some to help those suffering from ALS, & make them more comfortable, as well as helping those caring for them

Date Submitted 2/22/2023

Juergen bergk

CMS Seat Elevation Comment    There are many situations where an elevated chair would help tremendously in the house getting elevated to get things from the pantry or to the countertops and the store to be able to reach products on shelves.

Date Submitted 2/22/2023

Ms. Rebecca M.

CMS Seat Elevation Comment    My name is Rebecca M and my brother-in-law is living with ALS. He uses a power wheelchair frequently as his legs will not allow him to walk very much any more. Having seat elevation included in his chair will enable his ability to communicate better. Currently his speech is very slurred. People have to crouch down to his level to which creates an unnatural speaking dynamic. Being at eye level will be a big help. Additionally, his primary care giver, and the rest of us in the family, are aging. Having a means to elevate him in his chair will make taking care of his feeding tube (which he needs for nutrition), brushing his teeth and other daily hygene tasks will be much, much easier. Full time complete caregiving is exhausting enough. This will be a god send. Thank you so much for proposing this change to Medicare! We appreciate all the support we can get to have this be approved.

Date Submitted 2/22/2023

Jolene Todd

CMS Seat Elevation Comment    Seat elevation is not a luxury for those living with ALS, it is a quality of life that allows a person living with ALS more independence. Seat elevation assists people living with ALS to reach countertops, sit comfortably at tables, get into a position to be able to get to a standing position with less assistance from a caregiver, when using a sit to stand machine it allows the person living with ALS to be in a better position. There are so many benefits to the seat elevation for a persons quality of life when battling this disease. Thank you for making this a reality, and one less battle to fight for families.

Date Submitted 2/24/2023

Denise M.

CMS Seat Elevation Comment    Being able to raise myself up would enable me to do many of the things I cant do now and make my life a little more livable. I find many things are out of reach for me since I am not able to walk or stand. The simple tasks such as getting clothes out of my closet, helping prepare meals, transferring myself into bed would all be a lot easier. Now I depend on my caregiver to do a lot of things that I could do for myself.

Date Submitted 2/22/2023

Mrs. Colette Stoehrmann

CMS Seat Elevation Comment    ALS is such a debilitating disease that eventually leaves the patient dependent on others for every detail of living. Any assistance they can receive through insurance is one less worry for them. I encourage you to add this to coverage.

Date Submitted 2/22/2023

George Hale

CMS Seat Elevation Comment    Its the right thing to do.

Spend on this to improve quality of life please

Date Submitted 2/22/2023

Ms. Shannon Todd

CMS Seat Elevation Comment    I have had the privilege to work with the ALS community for 13 years. Seat elevation in power wheelchairs is so important first in giving a person living with ALS more independence and ability to get more to eye level with conversations and to access environment but also for caregivers. If the person with ALS remains more independent this also frees time for the caregiver. The other large importance is for transfers as it is much easier to transfer someone in a wheelchair from a higher position down or a level transfer, rather than working to move someone from a lower level to a higher position.

Date Submitted 2/27/2023

Kent T.

CMS Seat Elevation Comment    Having helped my brother through ALS, it was very demeaning to my brother how much help he needed. I remember well when he could no longer get into or out of a wheelchair. He struggled so hard for a long time - just wasn't going to give up. There was nothing he could do. Allowing him the ability to get in and out of a wheelchair or any chair would have been temporary and very humane.

Please do the right thing by ALS sufferers. Give them a some lift in life

Date Submitted 2/22/2023

Sherry C.

CMS Seat Elevation Comment    Seat elevation made my life so much easier when my husband could not walk. He was able to lift the seat and scoot to the side and get into bed without me having to lift him. If saved my life

Date Submitted 2/22/2023

Lorraine Filone

CMS Seat Elevation Comment    i have known two young men with this sickness both having a wife and children. it is a slow death both physically and mentally for all concerned. any aid that is helpful should be afforded to the sick person and their families. it is heartbreaking and effects all.

Date Submitted 2/23/2023

Paul Gustafson

CMS Seat Elevation Comment    A family member of mine was diagnosed with ALS five years ago, and recently became unable to get out of her wheelchair. She and her husband were unable to afford the seat elevation option for her wheelchair, which has been a significant negative impact on her quality of life. Being able to elevate(she was able to try out a chair with this option) would be life-changing for her and have an powerful positive impact on her quality of life. I sincerely hope this proposal is approved.

Date Submitted 2/22/2023

Gary Shipp

CMS Seat Elevation Comment    Seat elevation is a critical component of high-quality supports for a person living with ALS. There is no known cause or cure for ALS, amyotrophic lateral sclerosis, also known as Lou Gehrig's disease.

By covering the cost of seat elevation for power wheelchairs, Medicare would be unlocking a higher-degree of quality of life for thousands of individuals while helping to minimize the physical and financial burdens associated with the disease. I urge support for this.

Date Submitted 2/28/2023

Ms. Daliah S.

CMS Seat Elevation Comment    My father just passed away from this miserable, horrific, unfair disease on Saturday. He was a prisoner in his body, and of course, in his wheelchair. Any additional mobilty/ elevation in a chair would make a mountain of difference to the PALS and their caregivers. Financial constraints shouldn't prevent a PALS from having this additional help.

Date Submitted 2/23/2023

Barbara Forster

CMS Seat Elevation Comment    Long over due.

Date Submitted 2/22/2023

Richard W.

CMS Seat Elevation Comment    I enjoy cooking. My wife and I take cooking classes when we go on vacation across the country. I cook 90 percent of our meals. Unfortunately, I have fallen 5 times in the kitchen standing at the counter preparing meals. I have a power wheelchair and elevating would help mitigate this risk.

Date Submitted 2/22/2023

Diane S.

CMS Seat Elevation Comment    My mother-in-law had ALS and has been gone for about 7 years. Had she had seat elevation on her wheelchair, it would have made her life and those caregivers around her so much easier. Her quality of life would have been better I hope and pray this gets approved to help those now. D.

Date Submitted 2/22/2023

Sue Trudeau

CMS Seat Elevation Comment    Anything we can do to help those suffering from ALS would be a blessing!

Date Submitted 2/22/2023

Ellen Bradish

CMS Seat Elevation Comment    Seat elevation is a very important thing for those with Al's, as it will increase the ability to change their positions and therefore decreasing chances for skin breakdown. It will enable the patient to have a different view of the world around them, which would help their overall mental status. It will also make transfers easier for care givers to make safe transfers. These people deserve this and other assistance. This debilitating disease is a nightmare for the person and its entire family and support system. Whatever it takes to assist in making their lives a little better they should receive. They can not change this cross they were given to live with so any help is greatly appreciated.

I am a friend of an ALS person and see the hardships this family is enduring. I try to help when I can. Please help them by passing this. Thank you,

Ellen Bradish

Date Submitted 2/22/2023

Joan K.

CMS Seat Elevation Comment    My husband was greatly aided by seat elevation in his power chair

Date Submitted 2/22/2023

Valerie S.

CMS Seat Elevation Comment    My brother in law suffers from ALS and it takes both my sister and I to help him out of his chair. Please support this action!

Date Submitted 2/24/2023

Bob Scannell

CMS Seat Elevation Comment    An ALS patient will likely be confined to their power chair for up to 24 hours a day. There are numerous reasons why seat elevation is important, including safety, self-sufficiency, and quality of life. Self-sufficiency should be given extra consideration. Many household tasks including accessing a microwave, a kitchen cupboard, a closet shelf, are impossible without the seat elevation. With so many other abilities striped from an ALS patient, self-sufficiency should not be one of them, when possible.

Date Submitted 2/22/2023

Marilyn A.

CMS Seat Elevation Comment    I am so happy that the seat elevation equipment for power wheelchairs will be covered by Medicare. My husband suffered with ALS and passed away in 2020 due to the complications of this disease. The last year plus of his life he was in his wheelchair from early morning till bedtime. We were lucky and were able to have a wheelchair with seat elevation and tilt abilities. I would add tilt ability to this bill. Elevation and tilt allowed for change of position when a patient is unable to do that for themselves. It made important daily jobs like g-tube feeding much easier for the caregiver and more comfortable for the patient. It allowed for better napping positions and even in the small things like allowing my husband to see out of a window better helped to improve his quality of life. This is a must for all ALS patients when they get to the point where they can no longer be mobile for themselves. Elevation and Tilt please!!!

Date Submitted 2/22/2023

Dr. Ellen P.

CMS Seat Elevation Comment    My husband died of ALS and seat elevation for his power wheelchair would have made a world of difference in his quality of life and mobility.

Date Submitted 2/22/2023

Bonnie W.

CMS Seat Elevation Comment    A power recliner was one of the most helpful tools available when my husband was diagnosed with ALS.

An elevated seat in a wheelchair would have been a godsend. Cushions and pillows were not always comfortable nor safe.

Its time for additional research into providing comfort to ALS patients as well as their caregivers! I know firsthand that I was NOT in a position to care for my husband in a way that was safe for both of us. His diagnosis was at the onset of COVID. So no clinics. No additional help. I could go on and on.

Please continue to provide financial relief for those suffering from ALS as well as tools for caregivers to remain healthy and safe.

Date Submitted 2/22/2023

Blake P.

CMS Seat Elevation Comment    My brother just passed away from ALS on February 11th and his seat elevation equipment for power wheelchairs really helped his quality of life, please cover them.

Date Submitted 2/22/2023

Maryann Gorski

CMS Seat Elevation Comment    The elevated seat in the wheel chair was a life saver getting my husband in and out of the hospital bed and the coach. They also feel better when the seat is raised so they are eye level when talking to people. The seat enables them to reach more places like counter tops and cabinets.

Date Submitted 2/22/2023

Mrs. Judy Nail

CMS Seat Elevation Comment    Anything that could make things easier for the ALS patients and/or caregivers should be automatically approved.

Date Submitted 2/22/2023

Mr. Ray S.

CMS Seat Elevation Comment    My wife died of ALS. On a standard wheelchair she had trouble reaching many household items, such as the bathroom sink or the kitchen stovetop. Later as her neck muscles became weaker she could not look up at people which was very humiliating to her.

Date Submitted 2/22/2023

Bob P.

CMS Seat Elevation Comment    My leg muscles are so weak that I can no longer lift myself up out of my wheelchair to transfer anywhere. My Power wheelchair lift allows me to raise up high enough so I can safely transfer. Without my Power Lift I would have no way of transferring out of my wheelchair. A Power Lift for a person in my condition is a must have!

Date Submitted 2/22/2023

Mrs. Kathryn A.

CMS Seat Elevation Comment    Th being able to elevate my seat as needed I am able to be a little more independent and not have to depend on my caregiver n one more step of my own self.

Date Submitted 2/23/2023

Darlene Quiel

CMS Seat Elevation Comment    So many people with ALS are in wheelchairs because of this disease. Seat elevation in their wheelchairs can help improve their quality of life and help their caregivers with everyday tasks. I fully support the proposal for Medicare to cover this cost!

Date Submitted 2/23/2023

Miss Kathleen Severance

CMS Seat Elevation Comment    Give them more power to help move easier on their own or with little extra assistance.

Date Submitted 2/27/2023

Ms. Annette A.

CMS Seat Elevation Comment    My husband lost his fight with ALS in 2012, he did have a power wheelchair, and it was a very important piece to have if someone is dealing with ALS,

Date Submitted 2/23/2023

Vikki H.

CMS Seat Elevation Comment    I lost my 36 year old daughter in 2017. Her three sisters and I took care of her and her three children for three years before ALS took her. I am an advocate for ANYTHING that would make life easier for the caregiver or the loved one dealing with ALS every second. Thank you for this consideration.

Date Submitted 2/22/2023

Mr. John P B.

CMS Seat Elevation Comment    One of my best friends passed away from ALS 12 years ago. Anything to improve the quality of life would be most welcome for anyone suffering from this horrible disease

Date Submitted 2/22/2023

Elizabeth Branham

CMS Seat Elevation Comment    I am a friend to one patient with ALS and a family member to another person with ALS. The disease is horrible to begin with and comes with so many challenges. Mobile challenges come for nearly anyone with a physical disability depending on the circumstances. In my experience with dealing with mobility issues myself, I can tell you first hand that it is so much easier on the patient and on staff and caregivers when you have equipment that can make it easier for them to help get moved from one place to the next, from a chair to bed or chair to restroom. The higher the chair, the less strain on the patients body and the backs of anyone trying to help them up. Unless you've been in a situation where you literally can't do for yourself or have taken care of someone who can't, it's hard to imagine. Please help these patients get all the equipment they need to live their lives.

Date Submitted 2/22/2023

Wendy Dunkel

CMS Seat Elevation Comment    It shouldnt even be an option, it should be absolutely covered by Medicare.

Date Submitted 2/22/2023

Kathleen Phillips

CMS Seat Elevation Comment    Raising the seat on the power wheelchair is especially important for independence in the kitchen. Counter height, and stove height is higher than most seats and so the user is unable to do normal functions of cooking. A raised seat allows the user to chop or prepare foods on the counter and stir the pot on the stove. Very important for being more independent.

Date Submitted 2/22/2023

Kenneth B.

CMS Seat Elevation Comment    Support of seat elevation for ALS patients like myself is a simple yet highly impactful step in making my life with ALS a more livable experience. It will allow me to independently perform simple tasks that otherwise would have to be performed by a care taker. Beyond the obvious functional benefits of extending my independence to perform basic tasks in the kitchen, bathroom and many public spaces (counters, ticket windows, etc), it has a psychological benefit as well. Depression and anxiety often accompany an ALS diagnosis. A big catalyst for that is the fear of lost independence. Any measure to mitigate my loss of independence improves my mental well being. The simple act of being able to elevate and speak to someone face to face, vs them having to crouch down is an empowering experience, helping me feel more "normal" despite my challenges. All of these benefits increase my quality of life AND help avoid other potential costs associated with additional caregiver resources, mental health services/meds and avoidance of potential accidents; where had the elevation function been present, I might not have tried to stand or reach for something.

Simple common sense tells you including elevation functionality for ALS patients in wheelchairs is the right thing to do.

Thank you for your consideration.

Date Submitted 2/23/2023

Mr. Jeff Todd

CMS Seat Elevation Comment    Any improvement to help the person while in a chair is desperately needed.

Date Submitted 2/22/2023

Sharon R.

CMS Seat Elevation Comment    Seat elevation is essential for persons living with ALS. Seat elevation allowed my husband to get to standing to urinate at the commode, modified independently, for months longer than he could have without seat elevation. This allowed me as his wife to be able to work longer to support us and maintain our health insurance. The seat elevation also aided getting him to standing to transfer. This delayed the eventual need for using the hoyer lift for transfers. The seat elevation also aided in raising his height so that he could see out the windows easier, which is very important when a person becomes essentially housebound.

Date Submitted 2/22/2023

Janey Allen

CMS Seat Elevation Comment    The ability to have a face to face conversation with another individual is another way that we can meet those with ALS in the way in which they choose. Imagine the ability to engage with a room full of people and gain access to the conversations by not interrupting but joining into the conversation as if you were also standing.

Date Submitted 2/27/2023

Tara B.

CMS Seat Elevation Comment    My courageous and dear late brother only hoped fit a better future f8r others. Please continue in supporting passage of the legislation

Date Submitted 2/23/2023

Erin Ryan

CMS Seat Elevation Comment    The expenses for this disease are crippling. We need to offer as much support as possible. Theses changes and issues matter to everyone in the ALS community. It doesn't just affect those who have ALS but all family members involved. Every dollar raised, every event or outreach opportunity, every effort matters, is needed and counts. Seat elevation coverage is needed.

Date Submitted 2/22/2023

John Sprague

CMS Seat Elevation Comment    Can not drive if you can not get in.

Date Submitted 2/23/2023

Rebecca Adams

CMS Seat Elevation Comment    Any assisted aid that helps both patient and caregiver would be greatly appreciated.

Date Submitted 2/23/2023

Sandy G.

CMS Seat Elevation Comment    Im a person living with ALS and the last time I purchased a wheelchair I had to pay for the seat elevation out of pocket. Its a big bonus because now Im able to get into my freezer, get clothes out of closet, get mail out of mailbox. These are just a few things that the elevated seat allows me to do. The actual list goes on and on. Plus theres the psychological benefit of seeing another person eye to eye. Theres nothing more demoralizing than looking at someones waist, knees or buttocks deployed on how low your chair is. All of us with ALS would be more than grateful to get this passed. Thank you so much.

Gratefully,

Date Submitted 2/22/2023

Mr. Mark Friedman

CMS Seat Elevation Comment    Please help to improve the quality of life for people living with ALS by ensuring that people who are afflicted with this disease get seat elevation in power wheelchairs to help with their mobility.

Date Submitted 2/22/2023

Mr. Scott Furman

CMS Seat Elevation Comment    This is very important for people living with ALS. Please support this worthy cause.

Date Submitted 2/22/2023

Ms. Elda M.

CMS Seat Elevation Comment    Seat elevation will allow me to better live independently. I can be at eye level, cook without my body becoming tired and finally able to reach.

I am thankful for Medicare but this would be amazing

Date Submitted 2/22/2023

Mrs. Sue Mcmanemy

CMS Seat Elevation Comment    Get it done.

Date Submitted 2/26/2023

Ashlee C.

CMS Seat Elevation Comment    I have ALS and may need help in the future pretty much everything as do many people living with this disease. Caregivers and people with ALS could benefit so so much from seat elevation and prevent issues due to prolonged sitting in same position. Any help is a ton of help. Would be awesome.

Date Submitted 2/22/2023

Mrs. Tammy P.

CMS Seat Elevation Comment    This would have been extremely Helpful. For example a lot less bending over to help with daily things, like transfer from chair to bed or bath.

Having my mother with ALS feel apart of everything going on at eye level.

She at one point was unable to look up and with the Seat elevation she would not have to. This would be a benefit for her.

But more importantly the necessity would definitely be helping move her from chair to bed and bath because they are dead weight.

Thank you for considering the elevated seat this would mean a lot to those that are caring for a love one with ALS.

Date Submitted 2/23/2023

Mr. Ron Matusiak

CMS Seat Elevation Comment    needed moble chair

Date Submitted 2/22/2023

Stephanie Evans

CMS Seat Elevation Comment    Seat elevation in power wheelchairs is just simply an essential need and we are elated that Medicare will potentially cover the cost. Thank you.

Date Submitted 2/22/2023

Julie and Mike N.

CMS Seat Elevation Comment    My wife was diagnosed with ALS over 2 years ago. Her power wheelchair is an essential part of her daily life, the ability to raise and lower her chair tremendously helps her get into and out of bed, in and out of the couch and in and out of the toilet, please consider Medicare to cover this product

Thank you,

Date Submitted 2/22/2023

Audrey L.

CMS Seat Elevation Comment    My Mother, with ALS, used a loaner PWC with seat elevation. This function of her chair gave her access to items, like dishes and countertops, which were out of reach normally. It also was necessary in order for me to wash her hair by getting her over the sink, that really saved her back from extra painful bending. This function of the chair allowed her fuller access to her home and that improved her mood.

Date Submitted 2/25/2023

Jennifer B.

CMS Seat Elevation Comment    A chair lift would have helped my Dad tremendously as he cared for my mother each day. Please cover the cost of seat elevation. Thank you!

Date Submitted 2/22/2023

Elva Davis

CMS Seat Elevation Comment    Anything that would help a person with ALS be more comfortable should be considered for Medicare help.

Date Submitted 2/22/2023

Copeland West

CMS Seat Elevation Comment    As someone who has been in the healthcare field and surrounded by this disease within my immediate family for nearly a decade, the every day battle that patients and family members experience is unimaginable for most individuals who havent been touched by it. Any modality of care or treatment that can be of aid to these patients and their loved ones should be easily available to all that are afflicted. ALS is one of the few diseases that lacks one thing that most other diseases do not at this this point in time. Hope. These patients and their families deserve better from us as it pertains to the development of new treatments and the expedition of those treatments, as well as, any source of support that can be provided in everyday life for someone suffering from this relentlessly debilitating disease.

Date Submitted 2/22/2023

Courtney M.

CMS Seat Elevation Comment    ALS robs a person of their bodily functions, usually slowly and one at a time. Please take the time to imagine this happening to your child, your parent, your spouse, and yourself. Imagine relying on a spouse, parent, child, or stranger (if you can afford to hire one) to help you on and off the toilet - one of your most intimate, personal daily needs.

When my fathers ALS caused him to need assistance in the bathroom, he was absolutely adamant about not letting his adult children help him. This put so much strain, both emotional and physical, on my 70 year old mother. My siblings and I were left to helplessly let them struggle to get him on an off the toilet. As if being diagnosed with a terminal disease is not enough, my fathers sense of independence, dignity, and pride were slowly crushed.

Access to seat elevation equipment would have been a game changer. Quality of life for my father would have skyrocketed for his last few months. He would have been able to maintain his independence longer. My mother would not have to physically suffer with transfers. My father would not have felt like a burden.

ALS is a cruel disease. People living with it need access equipment that allows them to complete activities of daily living safely for as long as possible.

-Courtney M

Date Submitted 2/22/2023

Mr. Lee C.

CMS Seat Elevation Comment    I was a caretaker for my wife who passed away from ALS. The last year of her life she could not move from her neck down. At that point being safe mobile is paramount. Anything that can make lives safer and easier is essential for ALS patients.

Thank you

Date Submitted 2/23/2023

Terri Laughlin

CMS Seat Elevation Comment    I have a friend who was diagnosed with ALS 2 years ago. So far, he's doing well, but we all know what the future is bringing. Any bit of help his family could get to care for him as his condition worsens would be beneficial. I see absolutely no reason to not cover seat elevation as it would be a huge help to all involved.

Date Submitted 2/22/2023

Steven Wicks

CMS Seat Elevation Comment    Medicare covering seat elevation is important as living with this disease is extremely expensive. Also everything that can be done to make ALS patients difficult life just a little easier is the right thing for Medicare to do.

Date Submitted 2/22/2023

Joshua R.

CMS Seat Elevation Comment    We lost my father-in-law to this horrific disease a year ago next month. His life depended on the equipment he used every day and having a power chair with seat elevatation would have made his life just a little bit easier. This disease takes everything from those it impacts. The small victories are the only thing patients and caretakers have left when this disease takes hold. Powerchairs with seat elevation are one of those seamingly small victories that mean so much to the people devestated by ALS. By covering this necessary equipment, you have given people one more small victory, and with this disease, that's all we have left.

Date Submitted 2/22/2023

Anna Allen

CMS Seat Elevation Comment    This illness is arguably one of the most devastating illnesses in existence today. It is a diagnosis without hope where every day gets worse. ANYTHING we can do to help, we should.

Date Submitted 2/22/2023

Rachel Schuster

CMS Seat Elevation Comment    My neighbor was diagnosed with ALS and is in his early thirties. His use of a power chair helps him maintain some level of independence and normality in such tough times. They have three young girls of the ages 2, 5 and 7. As a care giver, it can be challenging for her to take care of all four family members. The power chair allows him to move indoor and outdoor with little assistance.

Date Submitted 2/22/2023

Mr. Jonathan "Brett" Everhart

CMS Seat Elevation Comment    I have a good friend whose dad died of ALS at 51. The wheel chair sat to low for him resulting in difficulty when he or then Melissa had to move him. Based on this experience I got involved doing photography for the ALS walks both in Denver and Fort Collins, Colorado. There were many there that could've benefited from the elevated chair. A very good idea to provide access to the community, it's one that has my heartfelt care.

Date Submitted 2/24/2023

Sharon H.

CMS Seat Elevation Comment    I am a person living with ALS. While I do not yet need a wheelchair, if and when I do it would be crucial to have the expense covered. Those who have the need now are likely in need of financial assistance for equipment to make quality of life better.

Date Submitted 2/24/2023

Mandy Rice

CMS Seat Elevation Comment    Medicare coverage of costs of seat elevation equipment for power wheelchairs would be a game changer for my dear friend living with ALS. His dear family who act as caregivers would greatly benefit as well. This is important to me as I do everything I can to support my friends.

Date Submitted 2/22/2023

Domingo B.

CMS Seat Elevation Comment    people living with ALS? lake me depends on seat elevation equipment for power wheelchairs! please Medicare: cover whit my plan thank you

Date Submitted 2/23/2023

Bobbie D.

CMS Seat Elevation Comment    This seat Elevation matters. One we lose muscle and nerves in our butts. laughs. Also unable to real or get out of a seat to . legs and arms some have no feeling at all . Even little things make big differences for our lives with ALS. it is the Humane thing to do . No one understands what someone with ALs goes through or the family . It would help the care taker with the person with ALS and also the person with ALs. Just to know our government cares makes a big difference in the little hope most have with this Diese. My family is hereditary ALs. My grandfather died from it and was in wheel chair and my father to . Now i have this ALS to and my kids and grand kids have 50 percent chance of getting it. Most ALS is paradic anyone can get. 10 percent is herediary like i have. Thank you . Bobbie D. Arizona Chapter

Date Submitted 2/22/2023

Lana B.

CMS Seat Elevation Comment    My husband is 46 and was diagnosed with ALS almost two years ago. He's 6' 3" and always had amazing posture and a recognizable stance and walk. As ALS has taken away his ability to stand up tall, or even stand for more than a minute, he's felt depressed as he's left out of the physical huddles that naturally occur in group conversations. Having the ability to sit comfortably and be at eye level again, would boost his mood, allow him to reach the kitchen appliances and counters again, and give him some sense of feeling like he used to. As a caregiver with four kids, it is challenging to have his meals and needs all prepped before I leave the house, since he can't reach the things he needs. A chair elevator would alleviate much of that. ALS is a disease that causes financial ruin for many. Not having the out of pocket expense for the elevator would be incredibly helpful to us and everyone.

Date Submitted 2/22/2023

Anna V.

CMS Seat Elevation Comment    My sister Pat when diagnosed with ALS was working in at Iowa State University. Pat ran the lectures committee with students, helping to facilitate bringing in national speakers from all areas to expand the students world and connect them to politicians, artists, writers, actors and all walks of life.

She worked so hard to stay mobile, a cane, then walker, then scooter and finally an electric wheelchair with position change capabilities, height adjustment, ability to recline and elevate feet. All of these positions helped her cope with the failing body. Swelling in feet, fatigue of head motion, arm rests moveable for arm weakness, raise the whole chair up to table, ability to have chair up to give an improved ability to talk to someone as her voice weakened probably a thousand more examples of improved life experience.

I want to implore you to realize how important these chairs are in the quality of everyday -in home or out of the house. The chairs also have the ability to attach assistive devices depending on the stage and needs of the person. The limits of ALS are tragic and the chairs give a slight bit of freedom to feel more normal, prevent additional medical complications and safely live their best life.

Date Submitted 2/22/2023

Mrs. Theresa S.

CMS Seat Elevation Comment    Seat elevation in power chairs will make transfers so much easier. I had to call for assistance for my husband just to get him out of the chair and into bed. Please approve this addition.

Date Submitted 2/22/2023

Amy Watkin

CMS Seat Elevation Comment    As I helped support my friend and her father through managing ALS, there were innumerable hoops to jump through just to get the access to basic needs including accessibility devices. We spent so much time doing paperwork, or just trying to decipher the paperwork. It was a huge struggle in terms of both time and brain power, and all of us have advanced degrees! Having to navigate these broken systems, running from one person or organization to the next to figure out how to get coverage for these things was exhausting. It took away the energy and time my friend wanted to have to spend with her father in his last months, weeks, and days. Not to mention the fact that while ALS itself was stealing her father's vibrancy, this broken process was stealing his humanity.

This isn't something that my friend's dad will ever benefit from, but I need it to be available to other people and caregivers trying to salvage a life and existence with this awful disease. In the most earnest plea that I can put forth, please include seat elevation in Medicare coverage. It will lighten an already heavy load for anyone who has to find a way to live with this disease.

Date Submitted 2/23/2023

Stacie V.

CMS Seat Elevation Comment    As a human, the elevator gives me the pride and dignity to speak to others at eye level, without having to be looked down upon.

As the residents of a nursing home, I am able to attend events and stay in the back of the audience out of the way of others a d still easily see the performance.

With the seat elevator, I don't just feel tall and proud. I am tall and proud.

Date Submitted 2/22/2023

Sandra M.

CMS Seat Elevation Comment    As a person who has lost 2 uncles, one aunt and one cousin to ALS, I think it's important to improve their shortened lives as much as possible. As a Speech Language Pathologist I know that proper positioning is important for communication to happen, seat elevation could certainly play a role in communication and increase independence. Thanks for your support.

Date Submitted 2/25/2023

Karen B.

CMS Seat Elevation Comment    My husband Robert J Had ALS disease The wheelchair came in handy for him to get around also when he passed away I Donated his for someone elseThank God that My husband insurance Pay for his I know there Or Some people are not blessed to have that kind of insurance So I was glad it gives it to someone that can use it

Date Submitted 2/22/2023

William E.

CMS Seat Elevation Comment    Out daughter-in-law died two years ago from ALS. Still today, her husband and the two children struggle to regain some financial security after the enormous amounts they spent on equipment and house changes to render her last two years liveable. Any assistance such as financing seat elevation chairs will help others. I include a video link to a song regarding her struggle: Holding On To Love.

Date Submitted 2/22/2023

Tamara K.

CMS Seat Elevation Comment    This is wonderful news. Seat elevation would allow my husband to have a better quality of life.

Date Submitted 2/22/2023

Mr. Charles D.

CMS Seat Elevation Comment    My wife (retired school teacher) and brother (retired Marine who fought in Vietnam) both battled and died with ALS. The seat elevation upgrade helped my wife look into my eyes and those of our children which gave her a sense of joy instead of people looking down on her always. Quality of life is impacted so very much when you are incapable of moving nothing but your eyes. The eyes brome your voice and expression of love.

Date Submitted 2/22/2023

Mrs. Kimberly A.

CMS Seat Elevation Comment    My mother passed away in 1998 from this horrible disease. I was her care taker. It was very hard on us both physically to move her from place to place, much more taking her places. I did though and dont regret one moment. But, my back has never been the same.

I pray you will decide to provide this equipment, their lives are hard enough.

Date Submitted 2/23/2023

Jason Hamman

CMS Seat Elevation Comment    Elevated seats in powered wheelchairs would be a game changer for those living with ALS as well the caretakers. Please strongly considering covering the cost!

Date Submitted 2/24/2023

Mr. Matt R.

CMS Seat Elevation Comment    Please consider seat elevation in powered wheelchair coverage. For those of us that have had family and friends die from this disease, having seat elevation helps both the individualy maintain some additional mobility, but also the family and care givers who might not othersie have the physical ability to assist the individual. It is too late now for our family, but those afflicted now, and in the future, will greatly value and appreciate this coverage. If you do not know first hand someone who has fought this fight, call me and I will tell you about my father-in-law's fight, or the 4 others I know first hand.

Date Submitted 2/22/2023

Judy H.

CMS Seat Elevation Comment    My daughter was diagnosed with ALS a couple of years ago and I want to make sure she has the necessary tools to help in living with ALS in the future. This seat elevation will help everyone to help her. Please cover the elevation equipment for power wheelchairs.

Date Submitted 2/23/2023

Vincent F.

CMS Seat Elevation Comment    Seat elevation is very important in several factors for me. First and foremost in using it for getting into and out of my bed. Secondly for yhe use in bathroom needs and in reaching for necessities of every day life especially in the kitchen.

Thank you

Date Submitted 2/22/2023

Courtney L.

CMS Seat Elevation Comment    My mom recently passed off ALS. During the time we were blessed to have her here, we were lucky enough to have received the seat elevation through a grant, but it made a huge difference. Not only the psychosocial aspects like her being able to look people in the eyes at events, and looking in the bathroom mirror. But also when transferring her in and out of her chair, I was able to decrease the amount of lifting I did. I could lift the chair so that her legs were already extended then I just had to go the rest of the way. This was a huge improvement in my health to be able to better care for her at home and not have to resort to a residential facility. That would have been far more costly and honestly she wouldnt have survived as long as she did if she were away from family. Please approve this life changing equipment!!!

Date Submitted 2/23/2023

Jane S.

CMS Seat Elevation Comment    I am an advocate for my brother and several others who have since passed away from ALS. Any and all equipment meant to add comfort to those with this awful condition or assist caregivers who are prone to injury when moving one who no longer has the ability to move on his or her own should be covered by Medicare with no hesitation. This should pertain to any disease or accident that causes one to lose the ability to move without the assistance of another person or persons.

Date Submitted 2/23/2023

Nacole R.

CMS Seat Elevation Comment    Anything that can be done to assist a ALS patient in easier mobility, and could give any comfort and especially agency to a person that is dying from this unexplainably cruel disease, should be considered medically necessary. Since I imagine many people dying from ALS, like my father, are living at home and being cared for by family members whom, without a chair to assist, will have to lift and lower the patient. This is a huge physical burden for caregivers, exacerbates exhaustion, could also lead to injuries, etc

Date Submitted 2/22/2023

Jorjann H.

CMS Seat Elevation Comment    My brother recently died frm ALS. He waited a long time for insurance to cover his elevated chair. In that time he lost the ability to do simple things like access the kitchen counter. Please help other ALS patients by making their life as comfortable as possible.

Date Submitted 2/22/2023

Mrs. Marie Z.

CMS Seat Elevation Comment    Seat elevation would be beneficial to ALS patients during the daily transfer of the patient from bed to chair/Chair to bed. It would allow the patient to be on a closer level with the surroundings and other people trying to assist the ALS patient . It would have been very helpful for my daughter in her 18 year battle with ALS It would have been used several times a day during those 18 years!

Date Submitted 2/22/2023

Mrs. Angie C.

CMS Seat Elevation Comment    My mom has ALS and is in skilled nursing. Her powerchair is critical for her care and will need a new chair soon as some of the workers in skilled care do not know how to operate and are really rough on her chair. She relies on her lift in chair when no one is in the room to assist her. Many of the workers in facilities do not undersatnd ALS. A worker from an agency got mad at my mom a few months ago because she told my mom to sit up and my mom said i need the hoyer lift to get out of bed and the worker started looking under her bed which obviously she had no idea what a hoyer even was. This is just an example how important devices like a chair lift are medically necesssry for PALS. We really need in home care for my mom but medicaid and medicare do not cover that.. she went through her hard earned retirement quickly with medical needs. She needs 24 hour care that I can not afford. There have been days there was no one to feed her as she can not feed herself. There have been nights she hasn't received her meds until midnight and she needs them to help her muscles relax just a few of the difficulties of ALS.

Date Submitted 2/22/2023

Jim W.

CMS Seat Elevation Comment    My brother has ALS and sooner or later you will need a power wheel chair so this is important as he is retired

Date Submitted 2/22/2023

Thomas P.

CMS Seat Elevation Comment    It is good to hear of Medicare proposing to cover elevated seats for powerized wheelchairs. The impact this can have on a patient and caregivers quality of life and medical support is immense and really logically viewed. Helping them in navigating important movement with less stress and overcoming constant deteriorating and degrading physical strength and weakness as they attempt to perform daily hygiene cleaning, bathing, clothing, bathroom needs to just state a few. Daily basic quality of life functions are made a little easier to navigate. Medically, you are putting less stress on a person's body who's physical strength is deteriorating because of the disease. It also helps many patients potentially be more self sufficient and not reliant on others in performing hygiene and bathroom needs which is positive for their mental health, confidence, pride and quality of life.

Patients and caregivers need all the help they can in performing daily functions we take for granted and are having to bear unbelievable costs in drugs and care items just to survive daily in declining life.

I saw my extremely fit brother and friends suffering with ALS, struggle daily to perform simple things, as going to bathroom toilet, in or out of bed, etc. They are proud people who don't like to be reliant always on others, and to give them increased and less stressful performance with what little strength and pride they have left is the least we currently can hope to offer them.I lost my brother Michael and friends Dick and Jeff to this dreaded disease,all in 2021. I saw what some things such as a elevated seats could do but also the costs,physically and prices they had to bare or forego.

They have lost the quantity of life so we should medically continue to help them with their remaining quality of life

I humbly ask that Medicare go forth with this enabling benefit as well as any others needed to provide the best medical coverage and tools to improve the quality of life for all involved

Respectfully

Date Submitted 2/22/2023

George D.

CMS Seat Elevation Comment    Seat elevation is a must for patients living with ALS. Most importantly since I can no longer stand, the seat elevation in my power wheelchair allows me to turn off and on house lights, reach into the drawers of a hutch where I have to store my medicines, and to be able to grab my laptop off of the counter. I cant imagine surviving without seat elevation. I would not be as safe without the seat elevation. It should be covered by private insurers and Medicare.

Date Submitted 2/24/2023

Margaret R.

CMS Seat Elevation Comment    All ALS patients, including my dear cousin Joanie's son, Kevin G., would benefit greatly from coverage of seat elevation in power wheelchairs. Please consider covering this expense for these patients. Thank You!

Date Submitted 2/23/2023

Guido Duarte

CMS Seat Elevation Comment    People with ALS disease are having a progressive loss of muscle strength and moving of arms, legs or head are becoming more difficult as the disease advance, so is extremely important the aid of a seat elevation in power wheelchairs to improve the quality of life. Main benefits are:

A Power Seat Elevator allows the patient to transfer downhill, putting less stress on the arms and shoulders.

With the ability to move vertically, the patient can reach needed spaces and complete more daily activities on his or her own.

By eliminating the need to constantly reach overhead and over extend the arms, hand and head, one can reduce your risk for overuse injuries.

Getting eye-level with friends, family and colleagues not only helps the patient neck and back, it gives also empowerment and increases the patient well-being.

Date Submitted 2/22/2023

Mrs. Susan Delaney-Acquaviva

CMS Seat Elevation Comment    Hi,

Seat elevation is literally the difference between sitting in a wheelchair all day with the fear that it you get up you will fall and being able to safely get out of your wheelchair. It's something essential to ALS patients, especially due to the progressiveness of this disease.

In terms of caregivers, it makes moving a patient so much safer.

It is important to give patients safety and dignity wherever possible.

Thank you,

Susan

Date Submitted 2/22/2023

Jim L.

CMS Seat Elevation Comment    From the first moment when my wife sat in a power wheelchair with seat elevation, I saw a new confidence and a big grin on her face. Fortunately we had received help through Team Gleason to provide the seat elevation which was otherwise one more drain from our savings. The grin on her face said everything about renewed confidence that she could add to the quality of her diminishing life with ALS. It was the difference between feeling like a child looking up (trying to look up, in her case) to an adult, putting her more on a plain with other adults, and giving her the ability to have a face-to-face, eye-to-eye conversation with others. For my part, seeing her smile and enjoy the moments of sharing brings so much joy to my heart. With ALS, little things such as this mean a lot!

Date Submitted 2/23/2023

Mr. William Clarkin

CMS Seat Elevation Comment    Anything to improve the lives of people living with ALS is a must. Put yourself in their seat, and you'd want to be elevated.

Date Submitted 2/22/2023

Arthur S.

CMS Seat Elevation Comment    My wife, who passed away 12/31/2022, loved her eyesight elevation feature on her wheelchair. It made her feel like a normal person when communicating with others. I paid for the feature. This disease is so costly and mentally draining that making her feel better was a main focus of the purchase. The people with ALS are facing certain death and there is no way to know when that day will arrive. It allowed her to feel alive.

Date Submitted 2/22/2023

Mrs. Deborah S.

CMS Seat Elevation Comment    My husband lost his 14 year battle with ALS in 2022. Many of those years were spent in a wheelchair. He was fortunate to have had seat elevation capabilities on his chair. When our boys were younger they were very active in football and soccer. I would bring my husband to every game. Since he was unable to sit in the bleachers he would position his wheelchair next to the field. Inevitable, there was always a chainlink fence in the way. Without the ability to elevate his chair he would not have been able to see the games.Watching his boys play sports brought so much joy to my husband . This feature proved to be invaluable and certainly improved the quality of his life. He also took advantage of this feature at concerts, plays and other events where he needed to be higher in order to see.

Date Submitted 2/23/2023

Ann C.

CMS Seat Elevation Comment    I am a care giver for my husband who had ALS he passed away 2/6

Elevated Seating helps with circulation as well as trapped gas which

was a huge issue for my husband. Wish we had this

Date Submitted 2/22/2023

Dora Leal

CMS Seat Elevation Comment    Allowing ALS patients to be as independent as possible is extremely important. Having the elevation feature in wheelchairs provides this capability and gives caregivers a break. Please. Please ensure Medicare covers this.

Date Submitted 2/22/2023

Daniel Goodman

CMS Seat Elevation Comment    Think. It's just logical.

Date Submitted 2/22/2023

Mrs. Holly Doiron

CMS Seat Elevation Comment    Seat elevation would ease the physical burden of the caregivers and give the person with ALS feel less of a burden

Date Submitted 2/22/2023

Lynda Koch

CMS Seat Elevation Comment    Having a relative with ALS I can see how hard it is to maneuver. The elevation seat is necessary

Date Submitted 2/23/2023

Mrs. MaryBeth I.

CMS Seat Elevation Comment    My husband Terry was in a power chair for 2+ years. We personally funded the $2000 for the seat elevation because it gave Terry access to people for conversation in ways that normalized interactions and preserved his dignity while dealing with ALS. To look someone in the eye while speaking or listening is usual, 'normal'. To have someone lean down to speak to you is awkward for both parties and makes the person in the wheelchair feel exposed as "other than normal". ALS is altogether othering so to have a tool that removes some of the angst and restores a normal daily activity like conversation is empowering to the patient. As his wife and caregiver, the elevation also allowed us to still hug in a somewhat 'normal' way and that intimacy is so important when human touch and interaction has become problematic. It also allowed Terry to receive massages from hospice which was a self-care step that greatly improved his spirits. Providing seat elevation would bring quality of life to many ALS patients.

Date Submitted 2/22/2023

Maisie S.

CMS Seat Elevation Comment    When my husband could no longer stand on his feet, we had to transfer him from his power wheelchair to the bed and from the bed to the wheelchair a few times a day. Without the elevation function, we could not do this with my female caregiver and me. My husband, without any doubt, decided to pay an extra fee to add the function when ordering the wheelchair to prevent any of us from getting potential injuries. I am sure anyone who unfortunately needs a power wheelchair will appreciate the cost is covered by Medicare. Thanks!

Date Submitted 2/22/2023

Michele F.

CMS Seat Elevation Comment    My name is Michele and I am 47 years old. I have a rare form of ALS. It is called ALS4. It is slow progressive and effects everyone differently. My physical issues started when I was in middle school and have slowly gotten worse. I am currently able to walk but I have to be very careful since my balance is failing along with bad foot drop. My doctors at Hopkins recently suggested that I use a walker for short walks and a motorized scooter for longer walks to avoid injury and falling. At this point is hard for me to walk up stairs or get out of a seat without using my arms to lift me up. I feel that all insurance companies and Medicare should cover all power wheelchairs with no limitations!

Date Submitted 2/22/2023

Shekar D.

CMS Seat Elevation Comment    My wife is an ALS patient and it will be w great help to add additional support from Medicare for the wheelchair

Date Submitted 2/22/2023

Mrs. Ann Scott T.

CMS Seat Elevation Comment    Taking my son to a restaurant. His chair would not fit under a regular table. If ALS patients had the availability for the chair to raise up they can sit

comfortably under the high tables in the bar area where they also serve all foods from the menu.

Date Submitted 2/22/2023

Denise F.

CMS Seat Elevation Comment    My husband lived at home for eight years with ALS. I was his only caregiver. Being able to change his seat elevation was a natural part of repositioning. That might seem small but for a person who is confined to a wheelchair it is significant. As his caregiver, I cannot imagine my added physical stress when taking care of his personal needs had we not had the ability to raise his seat.

Finally, in the last few days of my husband's life the lift equipment (equipment that I used to transfer him from bed to chair to bed) broke down in mid-transfer. If I had not been able to raise the seat of his wheelchair to meet him at the point of breakdown I would have had to make panicked phone calls for help getting him safely into his chair. It's not just nice to have the ability to change the elevation the seat. It can be critical.

Date Submitted 2/22/2023

Jackie A.

CMS Seat Elevation Comment    As a person living with ALS, it is extremely important for me to be able to communicate with, share meals with, and socialize with others at eye level! We value the life we're afforded and we should not be discriminated against because of a health crisis that has effected our lives and impacted our families tremendously! I am human and like you, if you were in my position, am asking for any decent human would want. To live with dignity! ALS doesn't define who I am! Please have compassion for us! Thanks

Date Submitted 2/24/2023

Mrs. Melynn Sight

CMS Seat Elevation Comment    As you know ALS is almost everything about immobility. Having aides like this not only offers the patient independence, it help ensure caregivers can offer proper care.

Date Submitted 2/22/2023

Melody L.

CMS Seat Elevation Comment    My Husband Mark had ALS from 2010-2014. We paid for the elevation device on his power chair. The elevation device allowed him some mobility from power to non powered seating. It made huge differences in him fitting up to and under tables and desks when he still had use of one arm and hand. It was a huge help to me when he no longer had use of his lower half. Putting on his socks, shoes, and pants was easier when I didnt have to bend to the floor! Daily cleaning and shaving worked so much easier and toileting when he could assist and when he couldnt saved my back! It was easier to get him in and out of the chair with the Hoyer lift. And he could lower to use urinal in handicap equipped van or raise to see out the window. That elevation device gave us both more ability to travel and be flexible during the time he was still alive. It allowed him more dignity during his illness. We had the financial ability to afford that elevation device. Im glad it wont be a matter of financial ability for others in the future!

Date Submitted 2/22/2023

Mrs. Dina S.

CMS Seat Elevation Comment    My mom had ALS. She passed six months after being diagnosed. This was 13 years ago. We had no way to make her life easier. She did not have a wheelchair. She lost her voice first. If she had had a raised seat, she would have been able to reach things on the counter. She could have raised up to see her friends and family. Later she had the mask to breath for her, so she couldnt wear her glasses. She couldnt see much at all. Being able to raise a wheelchair seat could have gotten her closer to things and people so she could see them. We were in Hastings, Nebraska. Thank you for letting me weigh in on this decision. I think a raised seat would greatly improve the quality of life.

Date Submitted 2/22/2023

Jennifer B.

CMS Seat Elevation Comment    Imagine being unable to move without assistance? Your mind willingly tells your body to stand or use the restroom, seemingly basic commands in our every day existence. However, this feat is insurmountable due to your recent diagnosis of ALS.

This was my Mom's routine, as she heroically battled this unrelenting disease. Facing each day with this dilemma, how to move without a struggle. Having seat elevation in her wheelchair would have made a enormous difference in her request to move, something many of us take for granted. She valiantly used most of her strength to move from a seated position to use the restroom or simply change the scenery from one room to another. Venturing outside was feasible but limited based on her strength that day. Seat elevation with her wheelchair would have increased her feeling of independence, a long forgotten side effect of ALS. It would have aided those caring for her a reprieve in the their daily routine of helping her.

ALS not only robs those affected with simple tasks but also places stress on caregivers who wonder how to help those transfer to chairs, wheelchair vans, restrooms, and to bed. Can you fathom the amount of times these routine exchanges were met with worry and a carefully thought out plan to provide my Mom with some semblance of normality in her battle? Please consider providing this cost for ALS patients and caregivers. They deserve better than having their battle dictated by a loss of the freedom to move.

Thank you.

Date Submitted 2/25/2023

Carrie Lau

CMS Seat Elevation Comment    Wonderful news!!!!! This should absolutely be covered as it is a necessity for those hit with this horrible disease.

Date Submitted 2/22/2023

Audrey Gallagher

CMS Seat Elevation Comment    Seat elevation is very important for patients with ALS. It is necessary for improving their quality of life while dealing with this disease.

Date Submitted 2/22/2023

Cindy B.

CMS Seat Elevation Comment    My brother suffered from ALS for 6 years. It stole his ability of movement, speech and even smiling. Getting the tools necessary to make his life the most comfortable was out of reach based on cost, when he was living at home. People suffering from ALS and their caregivers are robbed of so much, please help them in being able to obtain adaptive equipment, including seat elevation in power wheelchairs to help ease some pain and suffering from this terrible battle.

Date Submitted 2/22/2023

Ms. Patricia Flanagan

CMS Seat Elevation Comment    Please elevated seats!

Date Submitted 2/22/2023

Allison H.

CMS Seat Elevation Comment    My uncle was diagnosed with ALS when I was very young. Although I did not understand what was going on, I remember how deeply I was intrigued with the care he required and wanted to do all that I could to support him. Following his passing in 2013, I began to find ways to become more involved with those with ALS, which led me to pursue a doctorate in occupational therapy. Now in my final semester, I am becoming much more involved in the care of those with ALS, as my doctoral capstone project revolves around improvements in therapy services.

I have observed an overwhelming need for seat elevation, as it provides many improvements to each persons' daily life. Seat elevation may assist each person in functional transfers, weight bearing transfers, and their ability to participate with the environment around them. With increased assistance from the wheelchair for those aspects of their daily routine, it is likely to see a decrease in injury, decreased caregiver burden, and improved quality of life. Improvements in these areas can help to lower costs for medical care of those with ALS, as well as the need for caregiver assist/respite. This is a small change in policy that has the potential to provide huge improvements in care, and allow funding to be better dispersed.

Thank you for the consideration of the passing of this bill and I hope to see an official change soon.

Date Submitted 2/22/2023

Jimmie Cheek

CMS Seat Elevation Comment    As a former caregiver to someone with ALS this is one of the most important things they need. These power chairs are over$ 27000 back in 2015 most people do not have that kinda money. Its important for quality of life

Date Submitted 2/22/2023

Troy Alexander

CMS Seat Elevation Comment    I think it is great idea because as the ALS progresses getting up is harder as the Als patient.

Date Submitted 2/22/2023

'Nita B.

CMS Seat Elevation Comment    My brother-in-law is fortunate to be able to afford the seat elevation in his wheelchair. I see how easy that makes navigating for him.. My brother and sister-in-law developed back aches from having to lift my brother-in law. The lift has relieved them of that pain. From my experience I believe that everyone who has ALS would benefit greatly by having seat elevation equipment. I sincerely hope that Medicare will provide seat elevation equipment for those who need it.

Date Submitted 2/22/2023

Arthur (Dean) R.

CMS Seat Elevation Comment    This is Great news, I have Medicare, however, the Veteran's Administration provide my Excellent Wheelchair with elevated lift, that I use many times a day, to get bowls, plates, cups, etc. from the upper kitchen cabinets. Soooo necessary! Thank you for approving Seat Elevation for Medicare Clients.

Date Submitted 2/22/2023

Mrs. Dorothy M.

CMS Seat Elevation Comment    My sister died from ALS in 2013. The people who are suffering with ALS deserve all the help they can get for the two to four years they have.

Date Submitted 2/22/2023

Cathy Locnikar

CMS Seat Elevation Comment    Its the quality of life we are talking about why would that be in question? People living with ALS need whatever can make them more comfortable and if thats seat elevation in a wheelchair than that should be covered for them. Its a medical needed equipment and there should be no question about that!

Date Submitted 2/22/2023

John A.

CMS Seat Elevation Comment    As my disease progresses I become less independent and require more care by others, however, seat elevation would help prolong my independence so I am less needy. My wife is very small and it is difficult for her to help me up, dress me. Put me in bed, etc. There are so many benefits to help me if seat elevation was approved for us. Thank you so much for listening to our cry for help and quality of life.

Date Submitted 2/22/2023

Kim A.

CMS Seat Elevation Comment    I am a pALS, slow progression since diagnosis 3/5/2020. I received my power wheelchair in September of 2021. I was fortunate to get the seat elevation grant from Team Gleason. The seat elevation has allowed me to maintain my independence by being able to reach high cabinets, the microwave, bar height tables, and grocery shopping, without having to ask for help. I cant imagine not having the seat elevation. It shouldnt be just an option, its a necessity.

Date Submitted 2/22/2023

Cathy Geisler

CMS Seat Elevation Comment    Please add this coverage

It is a necessary part of being able to live in a world of different levels. Without the mobility to move on your own the ability to adjust a chair is huge! It is a necessity!

The quality of life would improve greatly and help those with ALS!

Please include these chairs in coverage!

Date Submitted 2/23/2023

Jill S.

CMS Seat Elevation Comment    My Dad died of ALS in 1991. My dream is a cure for this horrible disease before I die. Please give all suffering a chance to live a better end of their life!

Date Submitted 2/22/2023

Doreen S.

CMS Seat Elevation Comment    My husband had, and died from ALS. His mobility was terribly compromised. Have a motorized wheelchair was a blessing. To have a lift mechanism as well would have made it easier to adjust his body for comfort while in the chair. Also to lift him out of chair was very difficult for us both . If the chair would have lifted it would have been easier to get him out of the chair, and control his 280 lb body. I have back problems and hurt myself on many occasions. As his 24/7 caregiver, i could not be incapacitated. I could not afford this chair feature but inquired many times if available. ALS is awful on evryone involved but for critical lifting help, having a chair with this feature would have been invaluable. Thank you for your consideration

Date Submitted 2/28/2023

Dave Krupa

CMS Seat Elevation Comment    Do it, it's the right thing to do and it will help those that truly need help!!!!!

Date Submitted 2/23/2023

Kimberly Shuck

CMS Seat Elevation Comment    It would make it easier for caregivers when helping their als patient moving from chair to other places if they were able to elevate some. There is enough strain on caregivers bodies and anything to make it easier is best.

Date Submitted 2/22/2023

Jill S.

CMS Seat Elevation Comment    My husband was diagnosed with ALS in 2013 and died in 2017. For the last 2 years of his life he was in a wheelchair. We paid out of pocket to add seat elevation to his wheelchair. The diagnosis of ALS is devastating enough but when you are limited to being seated in a world of tall people, standing people, different table heights, and inability to adjust to sink heights, etc it makes life that much more challenging. Seat elevation in a wheelchair is not a luxury item. It is a necessary accommodation for management of ADLs for both the patient and caregiver.

Date Submitted 2/22/2023

Myrna B.

CMS Seat Elevation Comment    My Son is 46 and has ALS for7 years' seat elevation is very important for him. it improves his quality of live and self-esteem. he can't walk nor use his hands but with the seat elevation he can stand up (with my help) get better positioning etc ,help with transfers , drink and sit by tables etc

Date Submitted 2/23/2023

Cathy B.

CMS Seat Elevation Comment    Please for the love of GOD, do anything that may help someone living with ALS or a caregiver. I hope you NEVER have to live the nightmare. I lost my sister to ALS in 2000. She was 44 years old. She left behind a loving husband, a 10 year old son and a 4 year old daughter.

Date Submitted 2/22/2023

Cindy Y.

CMS Seat Elevation Comment    I have ALS and now have a power wheel chair with lift. It has made my life better!! I can get into and out of bed with the lift on the chair. I can stretch out my legs and tilt so I can get better circulation into my feet and legs. I can even lift to get into refrigerator and microwave now! This may sound simple, but the lift really helps you feel better physically and is needed by ALS community.

Date Submitted 2/22/2023

Barbara .

CMS Seat Elevation Comment    Being independent is so important to those of us living with ALS. I have struggled for 5 years trying to be independent going from a cane to a walker and now a wheelchair. A elevation seat on the power wheelchair would allow us to continue some normality in our every day living activities. This would also provide some relief to our caregivers.

Date Submitted 2/23/2023

Mr. Robert H.

CMS Seat Elevation Comment    I live in a wheelchair, the lift helps me sit at our island table. It also allows me to get to very comfortable positions and to be able to maneuver in tight places. It is extremely beneficial to be able to lay flat in an elevated position in order to change feeding tubes and trachs.

Date Submitted 2/22/2023

Mrs. Marty S.

CMS Seat Elevation Comment    My husband had ALS for 2 years before dying from this disease and I was his primary caregiver. As my husband's health and strength declined, it became more difficult on him and me to transfer him from his bed, to the chair, to the toilet, to the car etc. The process of helping him to a standing position from his power wheelchair always ran the risk of him losing his balance or me hurting my back. When we were blessed with an opportunity to use a wheelchair with a seat elevation feature (borrowed from an acquaintance) it was life altering. He was able to plant his feet and decide when he felt sturdy enough to attempt to transfer safely. It lessened the chances for us to inflict injury to him from grabbing and pulling his arms/shoulders. It gave him an opportunity to maintain his dignity a bit more, as opposed to people tugging at him to bring him to a standing position. A seat elevation feature should be the MINIMUM that is covered in motorized wheelchairs. They are an absolute necessity for an individual with ALS.. Please approve this asap.

Date Submitted 2/22/2023

Jessie Doll

CMS Seat Elevation Comment    This is fantastic news and my hope is that it passes with a unanimous vote! Seat elevation is so incredibly important for not only the caregiver and their physical well being but also for people living with ALS. People living with ALS have little independence and things that they can do completely on their own is very limited. It is difficult to have to depend on someone to do everything for you all of the time. With seat elevation this will give them more independence and maybe less depression. This is a depressing disease that affects their mental well being just as much as their physical well being. Seat elevation would also help caregivers by helping keep their physical well being in tack so that they can help with other activities. Often times caregivers are small and it takes multiple people to lift/help out of the seat. We should be helping people with ALS and their caregivers to live their best life and to help with their physical and mental well being. Thank you for your time and for listening to my thoughts.

Date Submitted 2/22/2023

Amy Easton

CMS Seat Elevation Comment    On behalf of every person with ALS, seat elevation is crucial for caregivers, transfers, quality of life, and the dignity of the person with ALS using a power wheelchair.

Date Submitted 2/22/2023

Jean B.

CMS Seat Elevation Comment    Hello! As a person living with ALS I support Medicare covering the cost of seat elevation systems for power wheelchairs. This feature saves the backs of our caregivers and allows us to transfer from chair to car, to bed and even to toilet with ease. Our ability to move slowly slips away. Please allow us assistive device to help retain some autonomy and dignity!

Date Submitted 2/22/2023

Karen P.

CMS Seat Elevation Comment    I am a caregiver and the seat elevation helps tremendously when I am transferring my husband. It lessens the load that I need to lift. It also helps when I need to brush his teeth or shave him.

Date Submitted 2/22/2023

Mrs. Betty Anne M.

CMS Seat Elevation Comment    My best friend of 58 years was diagnosed with rapid progressive ALS 3 years ago and died 6 months later. To have had a wheelchair that one could have used to raise her up and down would have been so helpful. I was an RN for 40 years and to move people around is so hard on the caregivers skeletal system. Also , it would help prevent injury to ALS patients so that there would be less likelihood to injure shoulder joints when needing to move them around. The patient would also benefit from being able to see things better as they are in these chairs for long periods of time. Sincerely, Betty M.

Date Submitted 2/22/2023

Kathleen Whelan

CMS Seat Elevation Comment    immobility and pressure sores are in an enormous concern in caring for people with ALS. Any more mobility that can be afforded them makes a profound difference to both physical and mental health.

Date Submitted 2/22/2023

Phyllis Palmer

CMS Seat Elevation Comment    This is a vital piece of equipment for ALS patients to be able to live with a tiny piece of independence. My family has familial ALS and many could have benefited from this before they died. 8 have suffered from this fatal disease in my family.

Phyllis Palmer

Date Submitted 2/22/2023

Mary E.

CMS Seat Elevation Comment    ALS is a devasting disease. My dad has it. There are SO many life changes and Daily Life Aides that are needed. Medicare should cover the elevation equipment for power chairs to make any part of a very difficult day easier.

Date Submitted 2/23/2023

Mrs. Rochelle A.

CMS Seat Elevation Comment    Thank you for listening, my husband has ALS, weve been together for six years hes had ALS for 10. The seat elevation is huge for his self-esteem. Can you imagine life having to look up at everyone, always? He can elevate to be more eye level with people. It helps him to feel more included in the airspace above four feet. BEven at church when the leader asks us all to stand, he has his own way of standing. Apart from that, and for more practical purposes, he uses his elevation so I can wash his hair in the bathroom sink, to position himself comfortably to see out of the van windows during rides, and even to move himself out of the reach of our pet, who likes to jump on his lap whenever she chooses. When ALS gets to the point of almost complete physical immobility, any flexibility the chair can offer is priceless to comfort and functionality.

Thank you!

Date Submitted 2/22/2023

Lisa P.

CMS Seat Elevation Comment    I lost my mom to als 12 years ago. My dad was her main care giver. She did not have a power wheelchair just a regular one. I know that if she did have this type of wheelchair with the seat elevation it would have made it so much easier on my dad and they would have been able to do more things together.

Thank you

Date Submitted 2/22/2023

Kevin H.

CMS Seat Elevation Comment    As a person living with ALS, I have difficulty getting out of chairs.wheelchairs are challenging due to the feet apparatus. My wife (caregiver) is small and cannot pull me up. It makes for an awkward and dangerous situation.

Date Submitted 2/24/2023

David St.

CMS Seat Elevation Comment    I use elevation to use bathroom, used it at my eye exam, used it at Dr.appt, and dental appt.TO RAISE TO MY WIFEs HEIGHT TO HUGE HER.when they say not medically necessary they havent had to use a wheelchair. I got diagnosed with ALS 11/20 and I have not looked back.I always dwell on what I can do today not what I did yesterday.without the elevator I would not be able to enjoy my life the way I live it now.My point of view is all power wheelchairs should have elevators on the so people can enjoy themselves more.

Date Submitted 2/22/2023

Luke K.

CMS Seat Elevation Comment    I am a 67 year old male diagnosed with ALS on Sept. 30, 2021. Thankfully I am not currently in a wheelchair but, I have concerns of what my future holds. ALS is taking away my strength and range of motion. Which ultimately affects my independence and quality of life. The seat elevation feature of a power heelchair enables the patient to move from the wheelchair to the bed or other transfer positions more easily than a chair without this feature. It' safer for the patient and the caregiver. In my case as I said, I'm 67 years old, my wife who is also my caregiver is nearly my age. I am 6 foot and about 180 pounds. She is about 5 foot 5 inches. Simply put, I am to heavy for her. I believe ours is the normal situation where the caregiver is tasked with handling a person who is bigger than she is. Please move forward with your proposal to cover the cost of seat elevation equipment for power wheelchairs it will help us patients hold on to some independence and quality of life and reduce the chance of injury to our caregivers. Thank you. Luke k

Date Submitted 2/25/2023

Ms. Sarah Sellers

CMS Seat Elevation Comment    Seat Elevation would allow individuals more independence, less isolation, and the ability to have access to their communities.

Date Submitted 2/22/2023

Colonel Ret Dr Eric L.

CMS Seat Elevation Comment    How does or would seat elevation in power wheelchairs improve the quality of life for you or other people living with ALS?

Seat elevation would improve our quality of life by helping us to do our morning toiletries at the sink, to reach plates and bowls and food items in upper shelves, and to see above peoples heads at the Performing Arts Center or the sports stadium/center.

How does or would seat elevation in power wheelchairs improve the life of caregivers?

Seat elevation in power wheelchairs would improve the life of caregivers by allowing them rest time while we do our morning toiletries, prepare to eat our meals, and sit to watch the theater or sports.

Why is seat elevation in power wheelchairs important to you?

Seat elevation in power wheelchairs important to me because I have limited autonomy currently, relying on my wife to be my caregiver for most everything. The seat elevation would give me more autonomy and the feeling of being human again.

Thank you.

Date Submitted 2/22/2023

Mrs. Christine Moretti

CMS Seat Elevation Comment    ALS robs you of everything. At least let patients retain some of their dignity by allowing them to be level with people in conversation by way of seat elevation on their power wheel chairs.

Date Submitted 2/22/2023

Tom and Carol D.

CMS Seat Elevation Comment    Thats about time they do that. Our daughter in law has this horrific disease and when they got her chair had to pay for the elavation feature themselves. Will they reimburse them for that. Its unreal the things they have had to pay out of pocket. Its a wonderful feature. Its gets her at everyone elses level so she not isolated. Anything that helps these victims should be paid for. Its so heartbreaking to see this beautiful woman go through this without a good outcome.

Date Submitted 2/22/2023

Jim M.

CMS Seat Elevation Comment    If I didnt have an elevator I would have been totally confined to my wheelchair years ago. I use many times a day from getting myself in and out of bed. I use it to get access to our microwave oven to reheat my food. I also use it to get in and out my lift chair plus getting on my toilet. Thanks Jim M Pittsburgh,Pa

Date Submitted 2/22/2023

Gina B.

CMS Seat Elevation Comment    We are wxtremely fortunate that the VA was able to give us a wheel chair that elevates it makes it a lot easier foi transfers and to change the patients trach if they are vented. As a caregiver, I speak from experience. Thank You

Date Submitted 2/22/2023

Deborah Verzino

CMS Seat Elevation Comment    The care of patients with ALS is physical labor. Seat elevation is not just for the patient it is for the whole care team. Since ALS afflicts men more often than women the mobility equipment is incredibly important because the strength of the caretaker (usually a woman) vs the size of the patient (usually a man) is unfairly skewed. My family had a team of women thanks to daughters and wife and even so the movements for position adjustment and mobility for transfer were extremely difficult and took a team. We were lucky to have each other. Please give people this option for safe, accessible transfers.

Date Submitted 2/23/2023

Annabelle V.

CMS Seat Elevation Comment    Seat elevation in power wheelchairs would have been very welcome for my husband who recently passed away from ALS. It would have been helpful to me as caregiver also.

Date Submitted 2/22/2023

William F.

CMS Seat Elevation Comment    I am a veteran living with ALS. I have a power wheelchair supplied by the VA which is essential. I use it both to reach counters and shelves in cabinets of differing heights, and also to adjust to tables of differing heights to work and eat at. This capability also frees my home health aide from having to assist me with many activities.

Date Submitted 2/22/2023

Robert C.

CMS Seat Elevation Comment    Seat elevation is very important to my wife, who has ALS. The lift mechanism allows her to get a drink of water from the refrigerator. The lift mechanism allows her dignity, by elevating her to her associates so they can communicate eye to eye.

She has been using a seat elevator on her wheelchair for seven years. It allows her to feel independent. She has the freedom to do things that are important to her.

This little device provides a great deal to her self esteem and belonging within the church and community.

Date Submitted 2/23/2023

Joyce L.

CMS Seat Elevation Comment    Hello,

As an ALS patient who may end up in a wheelchair, I would love a chair with a seat that elevates. I am 510 and currently use a wheelchair to get around occasionally but have issues with being so low in the seat. As the disease progresses I may have to be in a wheelchair all of the time and would really like to be safe and comfortable. I thank God daily for my slow progression of this horrible disease. I can only imagine someone my height or taller, who has been diagnosed and has rapid progression spending their last days in an uncomfortable wheelchair that doesnt allow flexibility for their body. I pray that the people in charge take time to consider the importance of the seat elevation for anyone who has to live in a wheelchair.

Date Submitted 2/24/2023

Marc R.

CMS Seat Elevation Comment    Seat elevation is critical. As our muscles atrophy we cant stand up from low seats. Elevation mechanism allows us to stand up from a seated position, and to transfer to rollator.

Date Submitted 2/22/2023

 Christine Morley

CMS Seat Elevation Comment    Seat elevation in power wheelchairs would be a big help! It's difficult to lift patients out of their chairs, and impossible, in some cases for spouses or caregivers who may not have the strength. It's also difficult, if not impossible for patients themselves to get out of their chairs without the seat elevation. Please cover the costs for seat elevation equipment! TIA!

Date Submitted 2/22/2023

Becky Huntley

CMS Seat Elevation Comment    Seat elevation seems like a 'small' thing but would make a huge difference. ALS patients already feel out of control and moving more safely and easily would be one less place to feel precarious and out of control. And what a boon to already exhausted caregivers! thank you for getting this paid for patients!

Date Submitted 2/22/2023

Terri W.

CMS Seat Elevation Comment    My mom passed away from ALS. We could have used a wheelchair like that. We need more research on this. If you have never seen this happened to a love one. You would fight harder. It took my mom in a year half after being diagnosed. It was hard watching a woman that took care of a family and a major business. Go down as fast as she did.

Date Submitted 2/22/2023

Ms. Ellen S.

CMS Seat Elevation Comment    My late husband, who was diagnosed with ALS in 2013, had a rapid progression, which is typical of familial (genetic) ALS. He was fitted for a power wheelchair from Medicare, but it took months to arrive. In the meantime, the local San Diego chapter of the ALS Association kindly provided a loaner power wheelchair for him to use while he was waiting. That loaner chair had seat elevation, which allowed him to adjust it for dining, sitting at a desk, and lots of other functions that helped him enormously. When he got the Medicare-provided wheelchair, he was, of course, grateful to have it, but disappointed that it didn't give him the additional benefits of seat elevation, which would have made his life that much easier. I strongly endorse adding seat elevation for power wheelchairs.

Date Submitted 2/22/2023

Mr. Joe S.

CMS Seat Elevation Comment    My Mom died too young. Took her in less than a year.

Date Submitted 2/24/2023

Sherrie Pellini

CMS Seat Elevation Comment    Why not have this coverage for people who need it.

Date Submitted 2/22/2023

Mr. Jojo Garza

CMS Seat Elevation Comment    ALS patients who arent mobile, feel free to move with motorized equipment. Makes for a better quality of life. Caregivers can provide quality care for their patients when not stressed out with having to do so much.

Date Submitted 2/22/2023

Amanda K.

CMS Seat Elevation Comment    There is no way my father-in-law will be able to pay for a power wheelchair. He is still in a manual wheelchair at the moment but the doctor has warned us as to what to expect next.

Date Submitted 2/22/2023

Efrain G.

CMS Seat Elevation Comment    Each small win is a HUGE win for ALS patients like me! Find a cure please!

Date Submitted 2/23/2023

Gina P.

CMS Seat Elevation Comment    Gone too soon. Theres no other way to put it. He was my dads best friend, my uncle and my godfather. He was everyones go to guy for a good laugh, helping hand or a buddy to fish or hunt with. I know these elevation wheelchairs would have helped my uncle do all the things he loved as he neared the end of his journey. I want to see others be able to enjoy their time here and do what they love. No one should suffer or feel different. I also feel blessed that this is happening on his 2 year anniversary of his death. Good things are happening for those with ALS and I hope that continues. Thank you.

Date Submitted 2/22/2023

Justine Gillis

CMS Seat Elevation Comment    Seat elevation is a necessity in power wheelchairs. My cousin suffered with ALS for 7 years. Literally everything was difficult for her caretakers and especially for her. Something as basic as this could provide ALS sufferers just a little more assistance in dealing with daily living and potentially the ability to help themselves at times which would help to maintain just a little of the dignity that this disease robs people of. Please help by supporting this initiative.

Date Submitted 2/22/2023

Constance R.

CMS Seat Elevation Comment    I was diagnosed with ALS in Feb./2017 I have a motorized wheelchair, it helps with my getting around, because I cannot walk. The elevation for the seat in my wheelchair would be a great help to me to be able to reach my cabinet door for my medicine, It will also be a helpful to my caregiver to get me in the bed and the car. I can also reach clothes thats hanging in my closet. No one knows what its like to have this disease, and not have the resources that you need to survive. Please make my life a little easier by making the elevation of my chair paided by medicare. Thank you

Date Submitted 2/22/2023

Shelly S.

CMS Seat Elevation Comment    Absolutely a YES!! Every minute is so very important to those living with and caregiving during the struggle of ALS. ALS is such a tough assignment so anything that can help is much appreciated!!! My husband had a very short diagnosis of 11 months. We were able to get the seat paid for by team Gleason, for which we were grateful!. (but getting this okayed was just another thing to add to the list of to dos.) An automatic the seat is included would simplify a very full busy schedule just trying to survive this horrible journey.

Date Submitted 2/22/2023

Marc St.Pierre

CMS Seat Elevation Comment    This would vastly improve quality of living for both patients with ALS and the wonderful caretakers that support them! Please make this happen.

Date Submitted 2/22/2023

Seiko Miki

CMS Seat Elevation Comment    Seat elevation will be tremendously important in improving functionality for ALS patients (already limited) and help preserve their dignity. Bothe critical when dealing with a progressive & debilitating horrible illness such as ALS

Date Submitted 2/22/2023

Mary Ellen O.

CMS Seat Elevation Comment    My son died July 19, 2022 after a 3 year battle with ALS. He was 57 years old and left 2 beautiful children on their own.

It is a debilitating disease with no cure and affects every area of your ability to live a somewhat normal life.

However small a piece of equipment seems, it adds just enough a little something to help in their daily lives.

Please do whatever you can for all ALS patients.

I appreciate your time and thank you in advance for your help.

Sincerely,

Date Submitted 2/22/2023

Mrs. Deborah B.

CMS Seat Elevation Comment    My sister had ALS prior to her death. As her disease progressed she was not able to lift herself to move to a chair or bed. If her wheelchair had a power lift seat it would have made caring for her much easier and given her more dignity and quality of life.

Date Submitted 2/22/2023

Mrs. Shirley J.

CMS Seat Elevation Comment    I was sole caregiver for my husband who was diagnosed by Mayo Rochester 1o years before he passed in his sleep, really not anticipated at that time. These folks live with such a bad death sentence that if there is anything a patient and their caregiver believe would help improve their quality of life they should be allowed/helped to attain it. Whatever can help them to be positive and enjoy interacting with others can help im a pleasant end of life for all

Date Submitted 2/23/2023

Beverly O.

CMS Seat Elevation Comment    Although my husband has passed from ALS. The elevated seat for his wheelchair allowed me to care for him properly. Otherwise I would not have been able to dress him, transfer him or care for him on my own. In my opinion, it is vital to any caregiver to have this assistance. It also allowed my husband to stand erect, which she could never do without the elevated seat on his wheelchair.

Date Submitted 2/22/2023

Maggie W.

CMS Seat Elevation Comment    wheel chair elevation is so needed not only for the patient but also for the caregiver My son in law has ALS and has slowly lost use of his muscles and my daughter can no longer lift him up by herself thus causing injury to herself and possible to him. Thank you

Date Submitted 2/23/2023

Susan M. E.

CMS Seat Elevation Comment    The chair extendor on me wheelchair is awesome my caregiver takes advantage of the extra height to save her back a lot. I also use it to help brush my teeth help me brush my teeth and have a bit easier time with breathing please vote for its inclusion with Medicare chairs . Thank you. Susan m. E

Date Submitted 2/27/2023

Nancy Miringoff

CMS Seat Elevation Comment    The seat elevation will assist PALS with transferring, and it can prevent and reduce sprain injuries. It is more normalizing for a person to have a one-on-one conversation with direct eye contact. There is both a medical purpose, I.e. prevention of injury and a psychosocial purpose.

Date Submitted 2/22/2023

Bruce L.

CMS Seat Elevation Comment    My son has ALS, he will be 51 in October if he makes it, and the folks who make this decision only need to see the heart ach, pain, and stress for the person who is afflicted by ALS. The monetary wreck that ALS creates is enough to ruin a family who already is losing someone the love and cherish so all the help Medicare can give, all our government can give also please push anything you can for ALS, the afflicted so need your help, think of their families also, Thank you Dad of a ALS patient, {my son is Todd L, and My name is Bruce L} again thank you for helping out

Date Submitted 2/22/2023

Mr. James M.

CMS Seat Elevation Comment    It is very important to have the elevation seat for wheelchairs. This will make it easier to reach items in my cabinet if I need something. This will give me more independence.

Date Submitted 2/28/2023

Robert K.

CMS Seat Elevation Comment    My wife passed away from ALS in 2020. During our 3-year journey with this illness, her mobility progressively decreased to the point where the only control and strength she had in her hands. Through the donation of a wheelchair from another family who had a member die of ALS, we were able to get a wheelchair for my wife that did have elevationeven though at that time Medicare did not provide for it. What a blessing that feature was, both for my wife and for myself as a caregiver.

The greatest benefit was that it allowed my wife to maintain her human dignity, as it enabled her to maneuver herself up and into a position where she could communicate with others. It also made it possible for her to continue daily activities much longer than she would have been able to without the feature of elevation, which was a tremendous boost to her spirit. For me as a caregiver (and for the other caregivers who helped) it was a Godsend, especially toward the end, when transfers between bed and wheelchair were particularly challenging. Without being able to elevate the chair to an appropriate height for the bed, the process of transfer would have been much more dangerous for us and for her.

In my opinion from my experience, it makes no sense not to include elevation in wheelchairs for ALS patients. By excluding it, it just seems cruel to people who are already facing the prospects of being isolated and of being an undue burden on others as their disease progresses.

Date Submitted 2/26/2023

Diane R.

CMS Seat Elevation Comment    My husband suffered with ALS for 2 years. The last 10 months of his life were aided with the uses of a motorized wheelchair. With out this his quality of life would have been a lot less. To have a chair with elevation would have very been useful to him and his caretakers. It was a challenge to move him. He lost all mobility the last 4 months. Please consider the quality of life for those suffering from ALS. Anything that can be done to help them would be appreciated.

Diane R.

Date Submitted 2/22/2023

Suzanne W

CMS Seat Elevation Comment    It would allow for me to be more independent around house in reaching things that I haven't been able to in years. This helps my husband, my caregiver, by alleviating some of his duties involved with caring for me. This not only helps us with the physical part of my ALS diagnosis, but could aid in boosting more of a positive mental health aspect for both my husband and I. We would both feel more confident and hopeful with more accessibility options. This can carry over outside of the house as well, such as restaurants or other buildings where I may need to be to support my grandchildren, for example.

Date Submitted 2/25/2023

Kelly S.

CMS Seat Elevation Comment    My mother had ALS and eventually she could not stand up from a lowered seating position. This would greatly help patients with ALS.

Date Submitted 2/23/2023

Art J.

CMS Seat Elevation Comment    safety is the most important reason to have seat elevation available in a power wheelchair it makes for safer easier transfers for myself and my caregiver less chance of falls reducing injury and hospital stays better health thru better living

Date Submitted 2/22/2023

Patty Bertrand

CMS Seat Elevation Comment    Seat elevation for the power wheelchair makes it easier to care for our ALS patient and enables him to access things he couldnt otherwise.

Date Submitted 2/22/2023

Dina D.

CMS Seat Elevation Comment    I watched my father at 75-78 battle this debilitating disease with no cure! I watched my mother at those same ages trying to lift him and make him comfortable with pillows, remote coaches, hospital beds etc. The struggle was real!!!! These patients and caregivers need these chairs for day to day simple activities. My father cried knowing he was only allowed 1 wheelchair and kept putting it off until he needed it. This is am an that was working as a pharmacist until he could no longer walk and stand on his feet at the age of 75!!! Please help these people and give them a chair since there is NO CURE! From a Caring daughter......

Date Submitted 2/23/2023

Liz Doram

CMS Seat Elevation Comment    This is such a needed piece of equipment. It will allow the ALS patients to do more for themselves while they can. And helps the caregivers ( usually the spouse) please please cover this under Medicare. People work their whole lives paying into social security-only to be constantly turned down when it comes to retirement needs .

Date Submitted 2/22/2023

Susan W.

CMS Seat Elevation Comment    I think this is a great idea not only for comfort when a person is in the wheelchair all day but to prevent skin breakdown and pressures areas from sitting in one spot so long. ALS people are at high risk of infection too so this would prevent that too. I used to be a caregiver for my sister but I'm a nurse too.

Date Submitted 2/22/2023

Mrs. Carol Nagy

CMS Seat Elevation Comment    Please cover the seat elevation for ALS victims.

Date Submitted 2/22/2023

Mrs. Nickie S.

CMS Seat Elevation Comment    Seat elevation would allow me to reach water faucets, light switches. Also I could reach clothes in my closet and could hang laundry on outside clothesline thus helping my husband do laundry. I think I might even be able to reach the knobs on my stove and cabinets to cook a little. Again, relieving my husband of some meal preparation. I could get to sink to brush my teeth, comb my hair and wash my hands. I could water my hanging potted plants. I could help my husband shop for groceries by being able to reach items on the shelves. I have to have someone do all these tasks for me. The major benefit for me would being able to arrange my closet and picking out what I want to wear each day. I have had my power chair for over 5 years without seat elevation due to cost of $2500.00 at the time. Being able to do any of things Ive mentioned would help me feel a little useful and have a purpose. I had no idea at the limitation Id have when I got my chair. If I had known, I would have found a way to get that option.

Date Submitted 2/23/2023

Wynette W.

CMS Seat Elevation Comment    The elevation in my seat is wonderful! I am able to reach things, set stuff up on the counter as your arms cannot lift up anymore. I like that I can talk to people face to face and not look up.

Date Submitted 2/22/2023

Dale.

CMS Seat Elevation Comment    I was the caretaker of [PHI Redacted] for four years before passing. He was a very good friend of ours, and it was very important to him to be at the same level (eye contact) of other people when talking to him. He was very fortunate to have enough money to buy a wheel chair that the seat would raise. It helped him much mentally and emotionally.

Date Submitted 2/22/2023

Mr. Robert O.

CMS Seat Elevation Comment    I use my seat elevator to facilitate transfers out of the wheelchair. I can stand with assistance to transfer to another chair. This greatly reduces risk of injuries to both me and my caregiver wife.

Date Submitted 2/22/2023

Danielle H C.

CMS Seat Elevation Comment    I want to applaud Medicare for taking this important step in including the elevated seat feature for ALS patients. It's not only imperative in helping maintain the patients quality of life, and care management, it is beneficial to the caregivers too and protects both from getting physical injury during transfers. By elevating a chair during transfer it easier for the caregiver to stabilize the patient on to a transfer disk and rotate them to a bed or shower chair. It was a devastating expense for our young family when it was not covered for my now deceased husband.

Date Submitted 2/27/2023

Mrs. Kelly C.

CMS Seat Elevation Comment    This was not covered when my husband needed a power chair. It is a priceless option that many can not afford. This allows my husband to reach necessary heights and many tables, counters, and gives him the ability to have the height necessary to converse more effectively with others.

Date Submitted 2/22/2023

Rolando Martinez

CMS Seat Elevation Comment    It helps a lot

Date Submitted 2/22/2023

Charlie P.

CMS Seat Elevation Comment    My mother is my father's primary caregiver and she is unable to lift my dad out of his chair without the support of seat elevation equipment. Without it, she would need to hire expensive in-home help much more frequently.

Date Submitted 2/23/2023

Mrs. Amy G.

CMS Seat Elevation Comment    My husband weighs much more than I do. Trying to move him in and out of his wheelchair is extremely challenging and is impacting my health as a caregiver. A wheelchair which would bring him to a standing position/lower him into the chair would improve both of our lives dramatically.

Date Submitted 2/23/2023

Mr. John Pokipala

CMS Seat Elevation Comment    Its simple!

It makes your quality of life better & who doesnt like better?!

Date Submitted 2/22/2023

Sarah B.

CMS Seat Elevation Comment    As a 62-year-old woman who is 5'2 and 115 pounds, this feature would really help me provide range of motion and other cares to my 2 friends living with ALS.

Date Submitted 2/22/2023

Liz Jackson

CMS Seat Elevation Comment    As a retired physical therapist who lost a dear friend to ALS this past May, I am thrilled to hear this news. The benefits possible with a sit to stand power chair will be many, to those diagnosed with ALS. Each person's journey is different of course, but with proper assessment of function & need, seat elevation equipment has so much to offer. This feature can do much to enhance quality of life, provide opportunities for weight bearing, prevent the development of contractures & breakdown, as well as improving lung function. Many thanks to those who are working to make this become a reality.

Date Submitted 2/23/2023

Cheryl A.

CMS Seat Elevation Comment    Power wheel chairs being covered helps immensely. Most could not afford these chairs. It gives my daughter- in - law a sense of freedom and independence she could not have without it. It gives my son help with her having some independence and leaves him time to attend to other obligations he has as he is her sole caretaker. Please pass this and implement this legislation!

Date Submitted 2/22/2023

Julianne P.

CMS Seat Elevation Comment    My husband has ALS and FTD and is struggling with his lack of independence. It would make him so happy to be able do things for himself, especially since he can do so little. It would also help me delay getting a PCA because he would be able to stand up with the help of the chair. Thank you!

Date Submitted 2/22/2023

Mrs. Judy Pangborn

CMS Seat Elevation Comment    I have been an RN specializing in ALS and Home Ventilator Care for 35 years. I travel with patients and transport them to appointments, outings and events. It is imperative that they be able to speak with others at eye level which promotes self-esteem and independence to live as normal a life as possible. It is necessary to be able to see when in a crowd and be noticed as a person. It promotes ease of feeding for the caregiver when at a tall table such as restaurants and bars have. I believe it is vital for reducing caregiver back strain when administering personal and medical care. The tilt feature is also a requirement to prevent pressure sores by changing position frequently. Those facing a wheelchair for life must have the ability to be healthy and functional. I am a strong supporter of patient's rights to thrive.

Date Submitted 2/24/2023

Suresh P.

CMS Seat Elevation Comment    It will be great news for me since I have ALS since 1088 I will have spare feet since my own feet are not cooperating which are disable.

Date Submitted 2/22/2023

Spero V.

CMS Seat Elevation Comment    Need counter or bar height chair for shower, and wheel chair and scooter...Cant ever get up with normal chairs no strength.

Date Submitted 2/22/2023

Mrs. Colleen C.

CMS Seat Elevation Comment    This was not covered when my father was diagnosed and later died due to ALS. This is a God-send.

Thank you.

Date Submitted 2/22/2023

Jann V.

CMS Seat Elevation Comment    For ALS victims their wheelchairs are what connect them to the environment that is now their normal. As my husband's caregiver during our journey with ALS I cannot stress enough the difference it made in both our worlds to have the seat elevation feature on his power wheelchair. Not only did it enable him to participate in his care, it was a safety measure for both of us. When the seat was adjusted to the same height as his bed, his shower chair, the car seat, it took the strain and potential for injury from us of lifting him up, before sliding him from one surface to another.

With the seat elevation my husband could reach the kitchen sink, counters and cabinets, he could get things from the upper shelves of the refrigerator, he could reach the height of the bathroom mirror so he could shave himself, he could sit at his desk without having to transfer to a stationery chair, it allowed us to go to restaurants. When his disease progressed to the point that he could no longer assist at all in his care, the seat elevation feature was not an option; it was a necessity for me and his caregivers.

However, just as important as the physical asset, the seat elevation feature allowed him to maintain dignity, control and freedom for a longer period of time trapped in a disease that eventually stripped all that away.

I encourage Medicare to cover the cost of seat elevation in wheelchairs from the time of diagnosis with ALS. It's necessary for physical and mental health, it's appropriate and it's the right thing to do. Thank you.

Date Submitted 2/23/2023

Lynn V.

CMS Seat Elevation Comment    I am caring for my 61 year old brother for a few days in order to give my sister-in-law some respite time. They had been using caregivers one day a week, paid out of their own pockets, but the caregivers can no longer lift him. The use of a power wheelchair would be a huge help and allow him to remain at home. Please approve this much needed equipment!

Date Submitted 2/22/2023

Benjamin S.

CMS Seat Elevation Comment    After living with ALS for almost three years, my younger sister at 41 passed away in July of 2022. Throughout the pandemic until her passing I would travel from St.Louis to Washington D.C often to help her family with daily duties and often act more as a caregiver as she felt most comfortable around family. Thanks to the many nurses and local ALS community the last few years were as comfortable as possible. That being said, I learned and witnessed how expensive and how many tools were needed to take care of someone with ALS. Anything and I mean anything to take the burden off the family is essential to make those final years as best as possible. Whether its medication, equipment, or experimental procedures, all of these can ease the pain and burden in so many ways.

Date Submitted 2/22/2023

Peter Squier

CMS Seat Elevation Comment    My best friend has ALS and it's been horrible to see his deterioration. Unfortunately, his wife is not strong enough to get him out of his wheelchair and into bed, his living room chair or the car. Having a wheelchair that can elevate him would greatly improve the quality of his life and his wife's live. Please approve Medicare covering elevated power wheelchairs!

Date Submitted 2/22/2023

Dean C.

CMS Seat Elevation Comment    Having these motorized mobile units is imperative for an ALS patient. My mother passed away from this horrible disease five years ago and I could not imagine her not being able to utilize a mobile unit for the last three years of her life. She was fortunate enough to be able to afford one without assistance, but Im sure that is not the case with over half of the patients who have the disease. Any help with the financing or coverage of these mobile units is imperative for those who cant afford it. Please consider.

Thank you

Date Submitted 2/22/2023

Rebecca T.

CMS Seat Elevation Comment    During my husband's five year battle with ALS, the seat elevation on his power wheelchair was important to his safety and mine, and was essential to him receiving medical care outside of the hospital. On countless occasions we visited physicians whose offices did not have any kind of patient lift. For him to be examined or treated he had to be transferred to an exam table, and he weighed 220lbs. With no use of his legs or strength in his back, he was helpless. I had to leave a sheet under him in the chair before we left home, elevate the chair to be level with the exam table, recline the back and raise the legs so he was laying as close to flat as possible, raise the arm of the chair and slide him across from he chair to the table. There was no other way. Without the seat elevation he would have not had access to much needed medical care outside a hospital setting (and one a couple of occasions at clinics inside hospitals). There were times when he lived and slept in that chair, and as his 24-hour caregiver, my back would not have survived bending over to dress, stretch, tend and treat him. For an ALS patient, the wheelchair elevation is as important as the hospital bed elevation to any other bedridden patient.

Date Submitted 2/23/2023

Martha W.

CMS Seat Elevation Comment    Once I was dependent on a wheelchair, I was not able to do simple things around the home. The seat elevation system has allowed me to stay independent in basic things like reaching something on a shelf and just being able to look out the window. It also helps the caregiver to be able to have you raised up to a level where you can be easily transferred to a chair or bed. I can't imagine life without this helpful tool!

Date Submitted 2/22/2023

Tiffany S.

CMS Seat Elevation Comment    My dad had ALS. We lost him in November 2021. He was diagnosed in February 2021 and the disease progressed quickly. My mom at 68 years old was his caregiver. My dad weight around 180 pounds and mom could not lift him. Having seat elevation on his power wheelchair would have helped in so many ways. I hope that you consider including this as not only would it increase the quality of life of the patient, but it would also ease the stress of the caregiver.

Date Submitted 2/22/2023

Ms. J. Venneman

CMS Seat Elevation Comment    Seat elevation allows for more independence and greater inclusivity in a variety of life events. Additionally, those who help with care are able to better care for individuals and save their backs and health in the long term. I urge you to support elevation in power wheelchairs as a way to keep individuals dignified and to provide safety to those who care for and love these individuals.

Date Submitted 2/22/2023

Heidi R.

CMS Seat Elevation Comment    As I supported my father through living and managing ALS, there were innumerable hoops to jump through just to get the access to basic needs including accessibility devices. Having to navigate these broken systems, running from one person or organization to the next to figure out how to get coverage for these things was exhausting. It took away the energy and time I wanted to have to spend with my father in his last months, weeks, and days and the toll it took on him further withered away his humanity after such a devastating diagnosis and prognosis.

This simple change to allowing seat elevation coverage through Medicare might seem small, but I promise that it's significant. My dad and I talked about his time left on earth as "dog years" so every hour we spent trying to find access and support was more like weeks for what time he had left. Don't allow this to be other people's experiences.

This isn't something that my dad will ever benefit from, but I need it to be available to other people and caregivers trying to salvage a life and existence with this awful disease. In the most earnest plea that I can put forth, please include seat elevation in Medicare coverage. It will lighten an already heavy load for anyone who has to find a way to live with this disease.

Date Submitted 2/22/2023

Tom kiely

CMS Seat Elevation Comment    Please approve seat cover elevation

Date Submitted 2/22/2023

Debra D.

CMS Seat Elevation Comment    My brother lived with ALS for 6 years. Anything that can help to make life a little better for those suffering with this heartbreaking disease will be greatly appreciated.

Date Submitted 2/22/2023

Ms. Lani W.

CMS Seat Elevation Comment    With ALS I couldnt manage some degree of independence without my powerchair seat elevation. Its not an option its really essential. Please cover this asap. Thank you!

Date Submitted 2/23/2023

Sharifah R.

CMS Seat Elevation Comment    Seat elevation for those bound to wheelchairs is so important. Thank you for considering to make these available to those who need them, especially ALS patients. My Navy veteran brother would fall much of the time during his last year and a power seat elevated wheelchair would have been so helpful to him.

Thank you.

Sharifah R.

Date Submitted 2/22/2023

Tania J.

CMS Seat Elevation Comment    My father was diagnosed with ALS 3 years ago. He is now 68 years old . My mother who is 67 is his primary care giver. The seat elevation would be a great help to them both as he nor she has the strength to lift him.

Date Submitted 2/23/2023

Vivian G.

CMS Seat Elevation Comment    As a person living with ALS, but this option would be life-changing for so many. Ive gone without items at the grocery store because I couldnt reach them. Being eye level to be better able to communicate. I know that getting in and out of the wheelchair can be very painful! This reduces the number of times this would be necessary, reducing pain in general. Please approve this.

Date Submitted 2/23/2023

Lynn E.

CMS Seat Elevation Comment    Seat elevation is so important when having a debilitating disease such as ALS. Not only for the patient, but the caregiver(s) as well. I was one of the main caregivers for my Dad who had ALS. Before we eventually got lucky enough to obtain the seat elevator for his wheelchair, it was almost impossible to provide him with the care he needed. This disease can paralyze you and that unfortunately did happen to my Dad. We needed the seat elevation to get him in and out of bed, in and out of his chair, on and off the toilet, in and out of the car, etc. All these things can be achieved without out it but definitely not safely. Moving these patients in an unsafe manner can cause them physical injury, physical injury to a body that no longer has the means to heal itself. It can also cause the caregiver injury to the neck, back, and any other body parts used in the transfers. I know in my situation, we couldn't afford to lose a caregiver. I just cannot stress enough how life changing tools like the seat elevator are for these patients. They need all the help they can get. Thank you.

Date Submitted 2/22/2023

Terry J.

CMS Seat Elevation Comment    My husband was diagnosed with ALS 5 years ago. He has been blessed with few health issues up until 6 months ago. Once he had COVID IN December, his legs became very weak. He has an extremely difficult time standing up from a seated position. We have been creative so far in coming up with seating options but there have been many falls, calls to neighbors, friends and family for assistance to pick him off of the ground. A wheelchair with a power wheelchair with elevation would make a world of difference because we both know that the future will be in a wheelchair. The wheelchair is low and hard for him to get out of now, not sure what we are going to do. I would hate to have to call 911 at all times of day and night for help if I cant maneuver him. The wheelchair would help him keep his independence just a little bit longer. With this disease, that is really all we can ask.

Date Submitted 2/22/2023

Carol Markham

CMS Seat Elevation Comment    Just a super "Thank You"!

Date Submitted 2/23/2023

Karen L.

CMS Seat Elevation Comment    My husband has als. Elevation in a power wheel chair would help a lot with lifting for me the caregiver and would give my husband more freedom for longer. Als is a horrid disease, please approve elevated wheelchairs and make our plight a bit easier. Thank you, Karen

Date Submitted 2/22/2023

Dorothy Echols

CMS Seat Elevation Comment    Please help the people who have this disease. A seat elevation would help them immensley. Thank you.

Date Submitted 2/22/2023

Susan Perryman

CMS Seat Elevation Comment    Seat elevation helps to prevent skin breakdown, helps with transfers, and the ability to reach areas that could not reach before. Thank you Susan Perryman

Date Submitted 2/22/2023

Debra Bagnulo

CMS Seat Elevation Comment    Cover all chairs that help.

Its proven to assist the care giver and the ALS person.

Date Submitted 2/22/2023

Beth Hickey

CMS Seat Elevation Comment    I ask that Medicare does whatever it takes to make ALS patients have quality of life.

Date Submitted 2/23/2023

Robert T.

CMS Seat Elevation Comment    Being afflicted with ALS I believe that an elevated seat is very important tool in care for the patient. Being unable to walk or stand without devices, an elevated wheelchair would be the best option. PLEASE EXPEDITE APPROVAL!

Date Submitted 2/22/2023

Kelly C.

CMS Seat Elevation Comment    My mother was diagnosed with ALS in November 2019, this disease took her away from me and my family in May 2022. During that time my husband, father, brother, and I would all lift my mother from different positions. When it got to the point where we could not lift her any more safely we had to rely on the generosity of Team Gleason to put in a lift for my mom's electric wheelchair. My mom was a small woman, she was 118 pounds, but lifting her when she couldn't give us any help was extremely difficult and unsafe for me and my family. Without the lift I really don't know how we would have gotten her safely to bed, to appointments, even basic things like using the bathroom. This is by far a necessity for ALS patients and caregivers.

Date Submitted 2/22/2023

Colleen W.

CMS Seat Elevation Comment    A seat elevator would help keep ALS patients more independent as the disease progresses. My Dad would have loved this if he were alive today - but unfortunately this awful disease took him to heaven in 2021. Thank you for helping others who suffer from this hideous disease.

Date Submitted 2/22/2023

M Gill

CMS Seat Elevation Comment    I was the main caregiver to my husband with ALS. Having seat elevation function in his power chair was critical to being able to perform basic activities of daily living such as sitting at different sized tables and counter tops to eat, wash his face, socialize, or use his computer. Seat elevation was critical for him to be able to maneuver up the ramp to enter his ADA equipped van to go to doctor, physical therapy and ALS support group meetings, and visit family. He would not have been able to get in the van if seat elevation was not possible. Seat elevation is critical.

Date Submitted 2/22/2023

Mr. Randall S.

CMS Seat Elevation Comment    As a former ALS Caregiver for my late wife, I found that wheelchair seat elevation was an absolute necessity. One specific example is when my wife needed dental care while confined to her power wheelchair. We were unable to transfer her to the dental chair but were able to elevate her, as though she was in a dental chair, so the dentist could operate on her at an elevation he needed. Without chair seat elevation, the dentist could not have provided the necessary dental service.

Date Submitted 2/22/2023

Mrs. Connie E.

CMS Seat Elevation Comment    Seat elevation is necessary for my father living with ALS. When he first started using his powerchair he was able to live semi-independently as he was only unable to walk and speak. The seat elevation enabled him to prepare meals in the kitchen which required him to reach items stored in cabinets and to stir pots on the stove top. It enabled him to reach the microwave and bathroom items stored in wall cabinets. When dining at home or in public, the seat elevation adjustment permitted him to adapt to the table allowing him to focus on his eating rather than his seating. As his illness has progressed and he has lost much of his independence the seat elevation feature is just as important but in different ways. When he goes to medical appointments (doctors, dentists, optometrists, barber, etc) he is unable to transfer to their chairs and his chair being able to adjust in all different variations has been vital to his ongoing care. It contributes to his quality of life as well enabling him to elevate in crowds for visibility and for accessibility in stores and other public places. The seat elevation also makes his chair more maneuverable. In a stationary position, there are elevation changes that would make navigating impossible as the foot rests would drag and prevent the chair from proceeding. With the seat elevation adjustment he can raise his chair, thus raising the foot rests, and he can continue forward. For someone with ALS, any amount of independence, safety, and security provided by their equipment is precious and necessary for their care. The sear elevation in power chairs definitely meets this criteria!

Date Submitted 2/22/2023

Mr. Jacquelynne Lamont

CMS Seat Elevation Comment    Please add this equipment as covered under Medicare as it is a wholly essential item that aids in the daily lives of those afflicted with ALS.

Date Submitted 2/22/2023

Debra B.

CMS Seat Elevation Comment    My brother was diagnosed with ALS and it's from when he served in the Marine Corps during Desert Storm and the Iraqi War. He was exposed to the burning oil fields, many different chemicals that were used. He is in constant physical pain which cannot be treated. Should he get to the point where he needs this wheelchair, I'd be so glad that he could receive one.

Date Submitted 2/23/2023

Michael L.

CMS Seat Elevation Comment    Greetings,

I received a power chair some years ago and had issues because the seat elevation was not included. It is difficult to reach anything on a shelf and I struggle with daily tasks. It would be great to have the option of a seat elevator which would make life much easier.

Date Submitted 2/22/2023

Mr. David C.

CMS Seat Elevation Comment    WITH SEAT ELEVATION I COULD NOT REACH THE FREEZER OR THE MICROWAVE, PLUS ELEVATION KEEPS THE FROM EATING MY FOOD

Date Submitted 2/22/2023

Michael C.

CMS Seat Elevation Comment    Seat elevation is IMPERATIVE for me because I am a 6'2" male. My caregivers are all much smaller than I. ALS has been in my family for 50+ years. It killed my grandfather before I was born. 19 years ago this Easter my mother was taken from us. Now the c9orf72 gene mutation is repeating inside me. It's just a matter of when. Help my caregivers deal with the hell that's to come. It will mean the difference between loved ones and strangers taking care of me.

Date Submitted 2/22/2023

Linda U.

CMS Seat Elevation Comment    My husband was a complete vegetable at 57 from ALS and his only way to see the light of day was being hoisted in the power chair. There is no way Medicare can be so cruel to take those chairs away from those suffering.

Date Submitted 2/22/2023

Susan D.

CMS Seat Elevation Comment    My husband and I met and married 8 months after we met. He was handsome, vivacious, healthy and loving. Two months after we married, he experienced foot drop which was then diagnosed as ALS. He was dead fourteen months later.

Alongside the love and support of friends and family, the power wheelchair was one of the only items that helped make this horrific disease bearable.

We were lucky enough to be able to afford a chair which would allow him to stand up and retain his dignity, lie flat or sit and many angles and make it a bit easier for me to care for him.

John was a tall, fit man and was very proud. He did not want anyone else to care for him. I was able to move him from the bed to the chair by using a belt tied around his waist and a transfer board. This only worked because the chair would like flat and allow me to move him.

I could also get him onto a shower/bathroom chair because of the elevated capacity of that miraculous chair.

We were able to go on "walks" together in the neighborhood, and I could get him into the retrofitted van to go on outings. This chair allowed us to enjoy the few precious months that we were able to spend together before he succumbed to the ravages of ALS.

We counted ourselves extremely lucky that we could afford the exorbitant price tag of that chair. It should not be a luxury as it is a necessity for anyone living with the paralyzing nature of this disease for which there is no cure.

Please find it in your hearts to make the last days of the people struck with this menace, as well as there loved ones a little more bearable.

Date Submitted 2/22/2023

Brian A.

CMS Seat Elevation Comment    I am living with als and I have lost the use of my hands and arms so elevated seats in wheelchair would benefit me greatly because with no use of arms I could not push myself out of a wheelchair

Date Submitted 2/24/2023

John D.

CMS Seat Elevation Comment    I've had ALS for 4+ years and I may be in need of a wheelchair soon. Today the wheelchair is covered by Medicare, but not the lift system. Please approve the entire wheelchair so I don't have to beg for assistance to cover those exceptions. Thanks

Date Submitted 2/22/2023

Patty U.

CMS Seat Elevation Comment    Cover Seat elevation can be useful for my husband (who is suffering with (ALS). It aids in the reduction & prevention of Strain injuries. Transfer from wheelchair to other surfaces such as beds and chairs are much easier with aid of an elevation system.

Date Submitted 2/22/2023

Cody Garcia

CMS Seat Elevation Comment    Seat elevation in power wheelchairs is important to me, as someone with no ties to ALS, is to ease transfer between wheelchairs and enable better quality of life for those living with ALS.

Date Submitted 2/22/2023

Kelly S.

CMS Seat Elevation Comment    My name is Kelly and I am fighting ALS. I do not have seat elevation on my wheelchair. It prevents me from doing many things or makes them more difficult. While I am weak in the arms, I still have use of them, and elevation would improve the quality of life I have with being able to do simple things like brushing my teeth at the sink, for example. Seeing eye to eye with others for a conversation so that everyone is not looking down at me. It would help me be able to get into the vehicle for a doctors appointment more easily - currently this is a true struggle. I would be able to reach for a cup in the cabinet to get a drink instead of waiting for someone to help me. It would open my options and allow me to do things with independence and less struggle - to try and enjoy life while I still have it. The quality of my life would be enhanced for sure and I would be so grateful.

Date Submitted 2/22/2023

Mr. Richard M.

CMS Seat Elevation Comment    My sister, Sue, died of ALS 25 years ago

Date Submitted 2/22/2023

Chelsea S.

CMS Seat Elevation Comment    Seat elevation helps the person with ALS feel more involved, and more able...at least I know my mom would have. May she rest in peace or fly on wherever she is <3 For a caregiver, this relieves strain and makes everyone more comfortable in many assets of daily life and caretaking.

Date Submitted 2/22/2023

Ms. Judith M.

CMS Seat Elevation Comment    My husband was diagnosed in 2013 with ALS and quickly moved forward on his ALS journey with the loss of use of his legs. The elevated wheelchair allowed him to function so much more on his own to keep his independence. It also allowed for physical therapy to keep some muscle tone while in the chair. Please consider improving the quality of life for the time that those suffer with ALS. He died in 2015 with dignity and gratefulness for those that supported him thru the journey. Judith M

Date Submitted 2/22/2023

Ms. Nina W.

CMS Seat Elevation Comment    I have ALS and I bought my chair over three years ago. I am so glad it had an elevated seat. Not only has it allowed me to see people at eye level when Im at parties or museums, but I can use it to raise myself to reach things that are on tables or shelves. It really makes a difference in my life.

Date Submitted 2/22/2023

Kelly White

CMS Seat Elevation Comment    PLEASE cover costs for seat elevation to be covered by Medicare. ALS is a horrible disease and is very expensive.

Date Submitted 2/22/2023

Ann L.

CMS Seat Elevation Comment    I lost my brother to ALS in June 2022. I witnessed the struggle that ALS patients have in dealing with all aspects of their lives. Anything and everything that can be done to improve the quality of their lives and those of their caregivers is essential.

Date Submitted 2/22/2023

Bourgon R.

CMS Seat Elevation Comment    This would have helped my Mom continue to live more normally for longer. Please cover this!!

Date Submitted 2/23/2023

Richard N.

CMS Seat Elevation Comment    My sister died from ALS and an elevating seat would have made it easier for her as her ALS progressed.

Date Submitted 2/23/2023

Randy Toombs

CMS Seat Elevation Comment    It would give a person living with ALS more independence

Date Submitted 2/22/2023

William W.

CMS Seat Elevation Comment    We are thrilled that Medicare is proposing to fund seat elevation devices for wheelchairs. This will make life much more efficient, and less wear and tear on me [with ALS] and my caregivers. Thank you for your ongoing consideration.

Date Submitted 2/22/2023

Bonnie L.

CMS Seat Elevation Comment    My husband has ALS and received his power wheelchair last week. A seat elevation is imperative to him so that he and others who need to would be able to reach new heights! Thank you for your consideration!

Date Submitted 2/22/2023

Mr. David P.

CMS Seat Elevation Comment    This is great news for ALS patients like me. It is a must for standing and for lying flat very hard to live without. This is a must!

Date Submitted 2/22/2023

Patricia B.

CMS Seat Elevation Comment    I answered this for myself earlier (I am the caregiver), but my husband who is a full time wheelchair user wanted to weigh in as well. A seat elevation in my power wheelchair would enable me to do many things others take for granted, like: Reaching the lock on a door, changing the temperature on a thermostat, being able to reach items on counters & cupboards, making transfers possible if there was not a powerlift available via a slide board, being able to work in a raised garden area in our yard, being able to talk face to face with someone as I cannot turn my head side to side and looking up to speak is quite difficult, being able to use the sink in the bathroom . This is just to name a few things that having a seat elevation chair would help .. I could probably go on and on given enough time to really write a list.

Date Submitted 2/22/2023

Elisa Kraus

CMS Seat Elevation Comment    People facing ALS are already robbed of so much. An elevated wheelchair provides invaluable freedom to to be more independent.

Date Submitted 2/23/2023

Ms. Susan Gordon

CMS Seat Elevation Comment    In adding seat elevation yo power chairs would help getting in and out of cars

Date Submitted 2/22/2023

Mrs. Sharon S.

CMS Seat Elevation Comment    I have to have a seat elevator or I would not be able to transfer from my chair to the toilet and my caregiver would have to do it and use a lift

Date Submitted 2/23/2023

Joan Robison

CMS Seat Elevation Comment    The elevating seat for the wheelchair is fantastic for everyone!!! Visiting with my friend of 44 years eyeball to eyeball is refreshing and we are able to connect on an equal level. Our last visit was so relaxed and lovely much like when we were in college 44 years ago! The elevated seat has given her much more independence and boosted her self confidence!

Date Submitted 2/24/2023

Allyson Sapp

CMS Seat Elevation Comment    ALS takes away motor abilities but doesnt take away mental. These people deserve a chair that allows mobility and elevation to do activities of daily living with dignity. This disease is a thief of ability, and a thief of life.

Date Submitted 2/22/2023

Bernard M.

CMS Seat Elevation Comment    I am happy to have the power lift on my chair.It allows me to have access to elevated items I wouldn't be able to reach.

Date Submitted 2/22/2023

Mr. Oliver K.

CMS Seat Elevation Comment    My wife had ALS , we had a power wheel chair for her and had to pay extra for a lift accessory. It made her more self sufficient to do dishes in the sink, set a a counter to feed her self while she could, to get a glass of water on her own, to help her stand to go to bed, and many other daily functions. To me all electric wheel chairs for ALS patients should have lifts as standard equipment and paid for to help them feel more independent as long as their able. ALS is very hard mentally on patients as they slowly lose their muscle control while their mind isnt effected It is one of the cruelest physical diseases a person can possibly have in ones life I saw her cry many times when she tried to do daily things but her body would not respond I dont know how she managed to keep her positive attitude during this very stressful time , a Belief in God cared her through knowing soon she would be pain free again Thank you

Date Submitted 2/23/2023

Dee Kuzniewski

CMS Seat Elevation Comment    It is extremely hard, sometimes almost impossible to move and position an ALS patient. Seat elevation and other positioning devices are a necessity.

Date Submitted 2/23/2023

Mr. Brian Mahinskr

CMS Seat Elevation Comment    Anything that would improve or make the living with ALS better, no matter how small or big should be covered by Medicare. And seat elevation in power wheel chairs is just that. The benefit to patient and caregiver is undeniable. The uses are numerous, easier transfer from chair to bed etc.., ease in personal hygiene care and the degree of dignity it provides is huge. To help someone move better and live better should be what Medicare is all about.

Date Submitted 2/22/2023

Emily S.

CMS Seat Elevation Comment    My uncle was given a power wheelchair by the ALS Foundation in his last year of life battling ALS. It was a crucial part of his day to day life, as it allowed him to move as he could not move his body. It also helped his caregivers as he could transport himself without them needing to carry him. Finally, the adjustable function of the chair allowed him to lay back and sit up, thus improving his blood flow.

Date Submitted 2/23/2023

Ms. Kristin R.

CMS Seat Elevation Comment    When my father was living with ALS, my mother was his primary caregiver. It was physically challenging for her to lift him to and from the toilet as well as in and out of bed or any time he needed to be somewhere other than his wheelchair. Having seat elevation is essential for both the patient living with ALS but also for the caregiver. It alleviates some of the physical strain that comes with caregiving for a patient with ALS and it also provides a bit more freedom for the person who has ALS, which is important for psycho, emotional well-being of the patient.

Date Submitted 2/22/2023

Janine Kelley

CMS Seat Elevation Comment    Any improvement for people with ALS and to make there life easy is a Win Win!!

Date Submitted 2/22/2023

David Hauser

CMS Seat Elevation Comment    Living with ALS is very trying for both patient and caregiver. Having the option to raise the seat position is very helpful to avoid the constant view of midlines and belt buckles. Avoiding eye contact due to lowered position takes away from the conversation and limits the effectiveness of the interpersonal dialogue that is so needed to maintain a sense of togetherness and community. Try watching any outside event in a wheelchair. The low position increases the difficulty and enjoyment. This is a very good idea to help patients cope with ongoing trauma the disease presents. Thanks for helping the handicapped.

Date Submitted 2/22/2023

Jessica Anderson

CMS Seat Elevation Comment    Eventually, a person with ALS relies solely on their power wheelchair for mobility and/or comfort. Because of this, they need to be able to raise and lower the wheelchair seat in order to complete daily tasks to maintain quality of life - examples: reaching for certain items that are higher, being able to have eye contact during conversations, assisting caregiver to provide better personal cares with more access to the body of the person with ALS. It seems to me, as an advocate, that the seat elevation feature should be a standard, covered piece of the power wheelchairs. They help people maintain their quality of life in so many ways.

Date Submitted 2/22/2023

Misha S.

CMS Seat Elevation Comment    My father was a physician and was diagnosed with ALS in 2016 and lost his life in 2017. My mom and I cared for him and without the seat elevation his life was altered and he could not perform his daily activities. In addition, our lives were altered as well as we many times faced physical restraints on our back, shoulder and arms from trying to have to move or elevate him. All of our lives were impacted due to lack of elevation. The quality of care was compromised and as a result we all suffered.

RIP Dr. Mohammad E S. (my father)

Date Submitted 2/22/2023

Marty D.

CMS Seat Elevation Comment    My wife passed away from ALS and I was her primary caregiver. Having the seat elevation equipment allowed her to better control the chair and it allowed me as caregiver, when she was no longer able to move, extra mobility which was necessary for transferring, eating, and improved overall comfort for her. I support Medicare providing the seat elevation as a covered expense.

Date Submitted 2/22/2023

Jo Anne J.

CMS Seat Elevation Comment    My husband has ALS and will likely be in need of a power chair with elevation in his future. We have heard from many others how important this elevation is to their mental wellbeing as it provides the opportunity for them to be on the same level with others to converse or at least feel a part of what is going on. Many of those suffering from ALS have already lost so much including the ability to walk, stand, eat, talk, use their hands or arms, that being able to feel part of the group can mean the world to them. I'm sure it also affords them the ability to reach something they need or be on the same level to reach out to hug a loved one.

Date Submitted 2/23/2023

Richard C.

CMS Seat Elevation Comment    I am living with ALS and it SUCKS!!! I was approved for the electric chair but not the lift option which was $1500. I was able to obtain a grant from the Gleason foundation and let my word be heard. It should be standard for ALS patients. I use the lift option every day for one to get in and out of the chair. It also makes using a sink to wash my hands very convenient. I also use it daily for my food. Rising up to counter level is sooooo useful. Also for having conversations with others rising to their level makes it less degrading. So to end here this option is very important for me personally. I couldnt imagine life without it. Just my two cents worth being lucky enough to have it.

Thank you for your time

Date Submitted 2/22/2023

Susan Ellis

CMS Seat Elevation Comment    Medicare should absolutely cover the cost for seat elevation for people with ALS. This is a cruel, debilitating disease no one should have to suffer. Please, give these folks any help you possibly can!

Date Submitted 2/22/2023

Gus Martschink

CMS Seat Elevation Comment    I am a retired Hospital Chaplain. I have observed patients & close friends and their families trying to use non powered wheel chairs unsuccessfully. Patient

Weakness & elderly family members cannot adequately or successfully use non powered wheelchairs.

Power wheelchairs and other power equipment should be a minimum requirement for all ALS patients! It is the least we can do to help the struggling patient and their familys.

Please do this ASAP! Thank you.

PeaceGus Martschink

Date Submitted 2/22/2023

Suzanne C.

CMS Seat Elevation Comment    My father and mother were both diagnosed with ALS in 2016-6 months apart. My father was a veteran and the VA supplied his power chair with seat elevation. My mother received her power chair thru Medicare and did not include seat elevation . The seat elevation provided so much more freedom for my father-to adjust to different table heights for eating, to facilitate getting him in and out of the chair. It would have been so much better if my mother had the same opportunity. Additionally I will say that getting my dads chair approve thru the VA was so much more straightforward. The Medicare process was incredibly challenging and lengthy. Particularly with the short life expectation. If I hadnt been available to pushthrough the Medicare paperwork my mother may have died waiting for her chair. In closing. Ive had experience with both parents with ALS. One with seat elevation and one without which gives me a unique perspective to advocate for it.

Date Submitted 2/22/2023

Mr. Matthew Patterson

CMS Seat Elevation Comment    A wheelchair seat that elevates would be another way to strengthen leg muscles. It would also make transfers easier for both persons living with ALS and caregivers. Weight bearing for persons with ALS I believe would give better absorbtion of calcium in bones. It also may give another option for doctors for weighing their ALS patients that can weight bear rather than a scale that can accomodate a wheelchair. Physical therapy options would increase also if persons with ALS had wheelchair seats that elevated. In addition, as a person living with ALS, it would be awesome to stand every so often and have a different standing perspective of the world. Thank you for considering having wheelchair seats that elevate for persons with ALS.

Date Submitted 2/22/2023

Maryann R.

CMS Seat Elevation Comment    After suffering for two years, my younger sister died a horrific death from ALS. By the end she was using a wheelchair, but of course she didnt have the strength to lift herself from it. That job sell to my brother-in-law, although he wanted desperately to be able to help her., he was suffering from pancreatic cancer, and with his chemo regime, he rarely had the strength to be able to lift her. Unfortunately, this legislation is too late to help my sister, or my brother-in-law, who died from his pancreatic cancer less than a year after my sister passed. But it is not too late to help thousands of other ALS suffers and their families. This is such a simple thing you can cover. But it would make such a big difference to so many people I encourage you to give final approval.

Date Submitted 2/22/2023

Dr. Larry Lewin

CMS Seat Elevation Comment    People living with ALS deserve seat elevation equipment for power wheelchairs. Medicare should cover the cost of this equipment.

Date Submitted 2/22/2023

I Nelson

CMS Seat Elevation Comment    My husband has ALS and I think Medicare should pay for not only the seat for wheelchairs but for recliners and walk-in showers for anyone with any disability

Date Submitted 2/22/2023

Tony Halford

CMS Seat Elevation Comment    Seat elevation would help those with ALS communicate with others when they are at a similar hight. Also when they are higher up they can see more, even when they have lost the ability to use their legs.

Date Submitted 2/22/2023

Mr. Tom and Lynn P.

CMS Seat Elevation Comment    My Son in law who recently passed away with ALS had seat elevation in his last wheelchair and it was an amazing assistance for him wherever he had to go out and be at a table etc.

Date Submitted 2/22/2023

Tiara R.

CMS Seat Elevation Comment    I received my electric wheelchair in June of 2022 and got a grant for it to be elevated. It has helped me to Stand without having someone lift me to transfer to chairs use bathroom facilities and bed. I am able to access items from the kitchen counters sink etc. I am still able to live in my home without requiring 24/7 caregiver care. This wouldnt be possible if I didnt have this chair. Living with ALS BETTER Thanks TF R

Date Submitted 2/24/2023

Carol V.

CMS Seat Elevation Comment    I am at the point in my ALS disease progression that standing up unaided from my wheelchair is nearly impossible. That means all the things I used to take for granted like reaching up for a coffee cup in the cabinet, taking a book off the shelf, pulling down a window shade, need to be done for me. Even more seriously, the movements that require assistance such as transfers to bed, to car, to toilet require my family members to lift me. It is a great strain on their backs even when done properly. A seat elevation in the wheelchair would save us all from frustrating and harmful struggling.

Date Submitted 2/27/2023

Mrs. Tamilyn P.

CMS Seat Elevation Comment    My 26 year old son had ALS and had an elevated seat wheel chair. This brought him so much dignity. He was asked to be a groomsman at his sisters wedding and could elevate his seat the be nearly the same height as the bridesmaid he went down the isle with. Also people didn’t have to bend down to talk to him, he would elevate at be at thesame level as them. For his caregiver, it made it easier for her to feed him and get him lifted into bed.

Approving payment through Medicare for this feature would be a great asset to anyone in a wheel chair for all the reasons I mentioned above.

Date Submitted 2/22/2023

Margaret D.

CMS Seat Elevation Comment    My sister is fighting the tough battle that people and their families fight with they have ALS. This coverage would be so helpful for her and the family. She has falling many times when trying to get out of her wheelchair for various reasons. She has black and blue marks all over her body due to these falls. Her son has been treated in the emergency department for muscle tares in his chest from lifting his Mom so she can use the commode, sit in her lift recliner, sit at the table to eat with her family, and picking her up after a falls. This type of equipment would make daily things a little easier for her and her family.

Date Submitted 2/22/2023

Mrs. Mary Johnson

CMS Seat Elevation Comment    This is great news for all ALS patients! My family has familial and having lost more than 16 loved ones, this is a MUST-HAVE, not a nice to have! Having the ability to provide assistance in quality of life, by easier moves and for caregivers the needed help to prevent hurting the loved ones as well as themselves!

Date Submitted 2/22/2023

Denby B.

CMS Seat Elevation Comment    Seat elevation is so much needed by us with ALS. To me it makes the difference between being able to shower and not. Being able to go to he bathroom. I'm 6ft4" tall so beinglifted while transferring is mandatory and so much safer. Being able to be lifted like I've mentioned is a lifesaver.

Date Submitted 2/23/2023

Jeff Doran

CMS Seat Elevation Comment    It has been 82 years since Lou Gehrig died of ALS. Despite the efforts of the ALS Community there is still no cure for ALS. So prior to a cure, what can be done to allow pALS to leave as normal a life as possible. One goal is to allow dignity in their daily life. One possible way to achieve this is thru "Seat Elevation" equipment for power wheelchairs. It would have significant meaning to be able to look someone in the eye when meeting in person. It would have significant meaning to be able to change positions during the day and alleviate bruises and skin condition common in pALS.

It would have significant meaning for caregivers to be able more easily care for us and be a positive moment for out families.

I urge you to take action and allow Medicare to cover the costs of this equipment. The cost weighed against the benefits is small, the gain gain be huge.

Thank you for your time

Jeff Doran

Snohomish WA,

Date Submitted 2/27/2023

Jill E.

CMS Seat Elevation Comment    My husband uses the seat elevation often. It helps him feel a little more normal in many ways. He has helped me trim trees by being able to hold the branches while I trim. He is able to reach his favorite clock on the wall and wind it himself. One most important feature of the seat elevation is that it helps immensely with his transfers to the toilet, lift chair and bed.

Date Submitted 2/22/2023

Stacey Lee

CMS Seat Elevation Comment    More funding for ALS

Date Submitted 2/22/2023

Mrs. Jacqueline M.

CMS Seat Elevation Comment    As a caregiver to my husband living with advanced ALS I benefit from our out of pocket purchase of his power wheelchair seat elevation every day. We use it in the morning to position him in the chair properly and comfortably. He elevates and tips his chair back frequently throughout the day to prevent skin issues and reduce swelling of his feet. He can have conversations eye to eye with me and friends and family. At the end of the day adjusting his chair height makes transfer out of his chair a safe process for me as well as him. For these and other reasons seat elevation in a power wheelchair is not a luxury, it is a necessity.

Date Submitted 2/23/2023

Jared C.

CMS Seat Elevation Comment    My son suffered from the ravages of ALS for two years before dying from its effects two weeks ago. During the last months, he and his caregivers were greatly aided by power lift chairs, one fixed that enabled him to stand and walk about, and one with wheels that enabled caregivers, mainly his wife, to wheel him to the bathroom and lift him to use the sink and the toilet. Access to this type of equipment is terribly important for anyone living with ALS and their caregivers. I strongly urge you to support Medicare coverage of these important devices.

Seattle, WA

Date Submitted 2/22/2023

Robert Gehrmann

CMS Seat Elevation Comment    Seat elevation improves the patients quality of life. Since they cannot move to change comfort the elevation can assist with that. Elevation can also help the caregiver making adjustments to the patients comfort by having easier access to those adjustments.

Date Submitted 2/22/2023

Kathleen S.

CMS Seat Elevation Comment    My brother lost his battle with ALS5 years ago. A wheelchair with seat elevation was not a convenience but a necessity.

He paid in to Medicare as we all have, it is NOT an entitlement. Medicare money belongs to the folks who paid into it, not the government.

Date Submitted 2/22/2023

Marsha R.

CMS Seat Elevation Comment    I am an ALS patient for approximately 2.5 yrs. Only 6 months ago, I required little assistance, but everyday this disease robs a once very active, independent person of strength to ambulate and remain independent. My most recent concern is difficulty rising from a low seat, especially if no chair handles. I have had to resort to a hydraulic lift device for my recliner and elevated toilet seat with handles. I have anxiety about being able able to arise from even handicapped toilets, and regular chairs, when away from home.As a result, I often opt to sit on my rollater seat in stead. I have not tried a wheelchair yet. I have requested wheelchair assistance in airports during a cross country trip to California in a few days. A power wheelchair has been reserved for my use at Disneyland during our visit with family. My biggest concern is being able to rise without assistance, from any type of seat, whether it be wheelchair, airplane seat and/ or toilet. My spouse is 84 years old with a bad back. He has tried, unsuccessfully before, to assist. Adding seat elevation to wheelchairs would greatly relieve anxiety in those of us with ALS. Staying engaged in normal activity, as much as possible, helps prevent fear and despair. I am blessed to have much to live for( spouse, 2 wonderful children and 3 young, delightful grandchildren). While adding chair elevation may seem a small measure, it would represent one less worry that those of us with ALS , as well as our families, have to stress over . Please vote to have Medicare cover cost of seat elevation. Marsha R.

Date Submitted 2/22/2023

Mrs. Patricia Marie G.

CMS Seat Elevation Comment    I have worked in healthcare with ALS patients. On a personal level my brother in law died of ALS. I learned that as the disease progresses preventing skin breakdown is a huge challenge. Sitting in a wheelchair lends to this. The elevating chair helps relieve pressure on the skin. It also allows the person with ALS to experience life at a standing level which is better for mental and physical health. Thank you.

Date Submitted 2/22/2023

Mrs. Jamie C.

CMS Seat Elevation Comment    My dad passed from ALS in 2008. This is a huge victory for ALS patients and we hope even more victories are to come. Thank you so much! Jamie

Date Submitted 2/22/2023

Ms. Laurie S.

CMS Seat Elevation Comment    My brother passed from ALS in 2001. I watched him try to maneuver himself up and down from seated positions until eventually it was impossible. His wife had to assist him each time. The disease is horrible enough coupled with humiliation of not being able to do anything for yourself breaks even the toughest of spirits. One must also consider the strength the care give must have lifting the person. Please pass this for all considered. Remember my brother Jeff H and his wife Cindy, and the countless others that will benefit from this equipment.

Date Submitted 2/22/2023

Renee D.

CMS Seat Elevation Comment    I am a caregiver for my mom living with ALS. I was the caregiver for my sister that fought the battle and lost to this beast of a disease. Having seat elevation in power wheelchairs is essential. I currently have to lift my mom out of the wheelchair with the help of someone else, using every ounce of muscles I have. With seat elevation the task would be substantially easier. She currently has a recliner with seat elevation and she also has a toilet with seat elevation. Both are extremely helpful as would be the seat in a power wheelchair. Please think about the ALS patients and their caregivers when making this final decision.

Date Submitted 2/22/2023

Brenda O.

CMS Seat Elevation Comment    I was my mothers primary caregiver during her battle with this terrible disease names ALS.

We were fortunate enough by having a powered wheelchair with seat elevation. This not only helped us in day to day activities. Her being able to reach the sink and grabbing a glass of water. This disease takes away completely the abilities a person, that anything small they can still do for themselves is motivational. Going out to the grocery store and being able to grab something from the top shelfs helps the person still fee somewhat independent.

Talking to family members and being able to see them eye to eye and not having to look up, especially when they begin to lose all basic functions of movement is incredible.

That small things make a huge difference in the daily living of people with ALS.

Date Submitted 2/22/2023

Mary D.

CMS Seat Elevation Comment    Seat elevation is important to my nephew and his wife. He was active duty military, tall and quite strong. He is now dependent on his petite wife to care for him. Any equipment and research is significant to their well-being and to that of their entire family who supports and watches this devastating disease.

Thank you for asking and for listening.

Mary

Date Submitted 2/24/2023

Claudia B.

CMS Seat Elevation Comment    My seat elevator helps me to be independent in my home. It allows me to give my caregiver a small respite from the constant demand that my care entails. I can get myself a glass for a drink of water, get a snack out of the fridge, and can open the blinds! It also allows me to eat at the table with my family rather than sitting below table height like a small child.

My seat elevator also allows me to transfer more safely to surfaces such as my bed which are not at the height of my wheelchair.

My seat elevator allows me to get to eye level with other people. This is empowering in conversation. It allows me to elevate myself to a height where people can see me when I'm in a crowded environment and allows me to get to counter height in places (like doctors' offices) where the counter is designed for people who are standing.

My seat elevator makes my life safer, more pleasant, and easier to navigate, and gives me added independence.

Date Submitted 2/22/2023

Charlotte Faris

CMS Seat Elevation Comment    SEAT ELEVATION HELPS PREVENT SORES, AND HELPS CIRCULATION IN ALS PATIENTS THIS HELPS THEM BE MORE COMFORTTABLE IN WHEELCHAIRS.

Date Submitted 2/22/2023

Don Ward

CMS Seat Elevation Comment    Please approve the coverage of elevation wheel chair for ALS patients. This dreaded disease takes everything from the patient. We are experiencing ALS first hand. It is a journey I would not wish on ANYONE. As well as stripping the inflicted person of their motility, humanity, pride, and appearance it drains their financial resources.

Date Submitted 2/22/2023

Mrs. Sally E.

CMS Seat Elevation Comment    As a former caregiver, sister died with ALS in 2013, the elevated seat makes it much easier for the caregiver and its less difficult for the patient. Please please please pass this.

Date Submitted 2/22/2023

Mr. David Bradley

CMS Seat Elevation Comment    als patients need support

Date Submitted 2/24/2023

Valerie B.

CMS Seat Elevation Comment    I am a person with ALS. I was diagnosed in March 2018 and by the summer of 2019 I was wheelchair-bound. I was so fortunate to have been given a wheelchair with that had seat elevation. It is so important when youre having conversations with people to be able to look at them eye to eye. If you have to sit in the chair and look up not only is uncomfortable for your neck, but it makes you feel like a victim or a patient. With the seat elevation, I feel like I am in the same conversation and people arent having to look down to me to talk with me. It is as much of a help for my physical wellbeing as my mental wellbeing. I strongly support this legislature being finalized. This disease is bad enough. Any break we can get is very helpful.

I am one of the lucky ones. I was given a life expectancy of 2 to 5 years. In a couple of weeks, I will be hitting that five year mark. I am doing as much as I can to advocate and educate. This is a no-brainer to me. Valerie O

Date Submitted 2/22/2023

Ms. Linda C.

CMS Seat Elevation Comment    Thank you for reading my reason why coverage in Medicare for power seats on wheelchairs for those with ALS is critical for them, and caregivers.

When my son was suffering from ALS every advantage to be comfortable, helping caregivers and feeling more included in gatherings is vital for everyone involved.

When Erik could raise up to counter height he was very happy he could try to cook for the family while he still had use of his hands. To see him feel a part of the family or even in any gathering was so important to his mental state as well.

This is a very expensive disease and every bit of financial help is important.

Thank you for moving forward to help anyone with ALS & those impacted by this brutal disease.

Date Submitted 2/22/2023

Ms. Patricia Folsom

CMS Seat Elevation Comment    As a caregiver for a person with ALS, it would make those daily living tasks like feeding, grooming, and dressing so much easier, and perhaps help prevent some backaches, and general fatigue. Caregivers have to take care of their own bodies to carry out caregiving for as long as they are needed.

For the person with ALS, it would enhance quality of life, especially in view of the fact that quantity of life may be lessened to 5-6 years, with significant physical decline in each of those years. One quality of life example would be to be for the person with ALS to be at eye level with family, friends, caregivers, and others, which relates to that whole issue in society of 'looking down at others'. Let's 'nip that in the bud'. Another quality of life item relates to going to museums and being enabled to view artwork at eye level, instead of having to look upward, which can be very fatiguing, and a person with ALS has only so much energy in his/her energy bank each day, and some of that energy can be depleted by the previous day's expenditure.

Date Submitted 2/23/2023

Shannon H.

CMS Seat Elevation Comment    Having a chair with seat elevation was essential to my mom who suffered from ALS. It improved our ability to care for her and her overall quality of life. I believe it was instrumental in keeping her in her own home during her battle with ALS.

Date Submitted 2/22/2023

Susan D.

CMS Seat Elevation Comment    The benefits of seat elevation seem obvious for increasing accessibility and comfort. I'm not in a wheelchair but am a short person, and I find most seats - my drivers seat, restaurant seating, etc. - too low for me. I have to sit on a cushion when I drive and also at my desk. It would be terrible for people in wheelchairs to have this additional burden in their already-restricted life. Being able to elevate the seat as needed would be a terrific feature for them.

Date Submitted 2/22/2023

Mrs. Linda M.

CMS Seat Elevation Comment    It helps make us feel independent. We need to feel as useful as long as we can to do things.

Date Submitted 2/22/2023

Mrs. Darlene P.

CMS Seat Elevation Comment    My husband could have benefited from seat elevation feature. It would have been easier access for me his caregiver to give him better care. like in transferring him, able to better access his feeding tube plus able to have options for his comfort. Please consider. if your quality of life plus knowing you have no choice to enjoy what life you have left.. wouldn't you'd want this feature. Thank you, Darlene P

Date Submitted 2/22/2023

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On behalf of the thousands of power wheelchair users among those we serve and our alumni, The Viscardi Center offers its heartfelt thanks to CMS for its support of the Benefit Category Determination that provides the empowering recognition that seat elevation systems in Group 3 are medical in nature and therefore are DME.

The Viscardi Center is particularly heartened that the NCD also proposes to find that these systems are reasonable and necessary for Medicare beneficiaries using Group 3 power wheelchairs when they perform weight-bearing transfers in the home, with or without the use of caregiver assistance or assistive technology, and undergo a specialty evaluation by a physical or occupational therapist in rehab wheelchair evaluations.

The Viscardi Center strongly supports the proposed decision, which expands access to this critical technology for people with disabilities who use a Group 3 chair, thereby promoting true health equity in those served by Medicare.

Furthermore, we recommend the extension of coverage proposal to improve reach & line of sight to support shoulder, upper spine, and neck integrity. Both the evidence and lived experiences of those served by Viscardi demonstrate the benefits of seat elevator for improved reach and line of sight for shoulder, neck, and upper spine function. Indeed, reach and line of sight are critical to improving wheelchair users’ wellness, safety within the home, and quality of life in general.

Additionally, The Viscardi Center supports access to seat elevation for users of Group 2 power wheelchairs. People with chronic medical conditions impacting cardiovascular and pulmonary function, lower extremity Acquired Loss of Limb(s), autoimmune diseases, and (Poly)Neuropathies. These individuals shouldn’t be categorically excluded from seat elevation simply because they don’t fit into the specific diagnoses that fit under the Group 3 coverage criteria.

Finally, we ask for clarity on the proposed limitations on the operational definitions of “weight-bearing transfers” and “Patient Transfer Devices” . The Viscardi Center calls on CMS to clarify these questions and ensure that all beneficiaries who would benefit from seat elevation are able to access coverage under the final NCD decision.

On behalf of the power wheelchair users represented by Viscardi, we thank you for your consideration of our comments.

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As a future OTA, my current semester has centered around assistive technology, including wheelchairs, and how the right tool improves the safety and quality of life for people. Power wheelchairs with seat elevation is not just a nice-to-have accessory option; it can make the difference between being dependent or independent in living situations. For example, having full, independent access the kitchen skin; using the stove without safety concerns for burns or fire; or reaching the microwave that is usually installed above the stove.

On the other hand, it can be useful for caregiver body mechanics, meaning they don't have to bend over to assist with taks and it makes transfers easier.

Additionally, the person's quality of life can be improved during social participation because being able to elevate up to eye level with peers, co-workers, healthcare professionals, and at checkout stations gives the person a sense of belonging and equality. There is a psychological component when it comes to always been literally "looked down on" that can translate into feeling looked down on and lesser than.

Our current environment isn't built with universal access in mind, so the next best solution is to give people requiring powered wheelchairs affordable options to live to their full potential and be treated as full human beings.

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March 17, 2023

SUBMITTED ELECTRONICALLY VIA Medicare Coverage Database Portal

The Honorable Chiquita Brooks-LaSure
Administrator
Centers for Medicare and Medicaid Services
7500 Security Boulevard Baltimore, MD 21244

RE: Proposed National Coverage Determination for Power Seat Elevation Equipment on Power Wheelchairs [CAG-00461N]

Dear Administrator Brooks-LaSure:

The ALS Association is pleased to support the Centers for Medicare and Medicaid Services (CMS) proposed decision memorandum to include power seat elevation equipment in the benefit category for durable medical equipment per Section 1861(n) of the Social Security Act. As previously stated in our September 2022 comments, we consider seat elevation systems reasonable and necessary equipment in power wheelchairs.

The ALS Association is the only national nonprofit organization fighting ALS on every front. By leading the way in global research, coordinating multidisciplinary care through certified clinical care centers, and fostering government partnerships, we build hope and enhance quality of life while aggressively searching for new treatments. Our commitment is that every person living with ALS, regardless of where they live, should be able to access high-quality care and equipment and effective treatments. Our goal is to make ALS livable for everyone, everywhere, until we can cure it.

We are committed to ensuring that all people with ALS have access to medical equipment that enhances their health and wellbeing and improves their quality of life. On behalf of the ALS patients and families we serve, we appreciate the opportunity to express our full support for Medicare coverage of power seat elevation systems for use by disabled individuals, including people living with ALS.

The ALS community values Medicare coverage of durable medical equipment and especially access to medically necessary technologies for people living with ALS. In accordance with the purposes expressed in the findings of the National Coverage Analysis (NCA), we agree with the consensus that power seat elevation systems integrated in power wheelchair systems are a medically necessary safety feature. These systems are especially necessary in the performance of non-level transfers and are useful in performing other medically necessary purposes such as assisting with activities of daily living (ADLs).

We applaud the decision and strongly encourage CMS to finalize its National Coverage Determination (NCD) for seat elevation systems integrated in power wheelchair systems.

Please contact Rich Brennan, Vice President, Federal Affairs, rich.brennan@als.org with any questions.

Sincerely,

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Dear Administrator Brooks-LaSure:

The Orthotic and Prosthetic Alliance (“O&P Alliance”) appreciates the opportunity to comment on the Centers for Medicare and Medicaid Services’ (“CMS”) proposed National Coverage Determination (“NCD”) for seat elevation systems in Complex Rehabilitation Technology (“CRT”) power wheelchairs. The O&P Alliance is a coalition of the undersigned five major national O&P organizations representing over 13,000 O&P professionals and 4,500 accredited O&P facilities that serve millions of individuals with disabling conditions in need of orthotic braces and prosthetic limbs.

We applaud CMS for proposing to recognize seat elevation systems as primarily medical in nature and reasonable and necessary for beneficiaries who qualify for this benefit. While we strongly support Medicare coverage of seat elevation under the durable medical equipment (“DME”) benefit, we offer these comments in response to the proposed NCD and urge CMS to consider revising its decision as noted below to ensure that all Medicare beneficiaries who need access to power seat elevation systems will receive coverage for them.

We supported the Independence Through Enhancement of Medicare and Medicaid Coalition’s (“ITEM Coalition’s”) submission in September 2020 of a joint NCD Reconsideration Request to cover both seat elevation and standing systems in CRT power wheelchairs. The value of being able to stand, bear weight on the lower limbs, and allow gravity to aid in metabolic functions is well established. Despite the fact that CMS accepted and deemed “complete” this joint request in November 2020, the agency bifurcated the NCD Reconsideration Request for seat elevation and standing systems into two separate NCDs. While the seat elevation NCD proceeds with this comment period, there is still no publicly available timeline for the opening of the NCD Reconsideration Request for coverage of standing systems in CRT power wheelchairs, a critical function that would highly complement seat elevation coverage and address another critical need of Medicare beneficiaries with mobility disabilities. We strongly urge CMS to issue the NCD Reconsideration Request for standing systems in Group 3 CRT power wheelchairs at its earliest opportunity.

Prosthetics, Orthotics, and Wheeled Mobility Technology

Nearly two million people live with limb loss in the United States, (Ziegler-Graham et al., 2008) and more than 185,000 amputations are performed annually (Owings & Kozak, 1998). For individuals with limb loss, prosthetic limb care is a key component of successful rehabilitative and recovery (Pasquina et al., 2015), yet a shockingly low number of amputees have access to prosthetic care. Within one year of amputation, only about 33 percent of amputees have received a prosthetic prescription, meaning roughly two-thirds of the limb loss population lacks access to limb prosthetics (Resnik & Borgia, 2015). Individuals with transfemoral amputations (above-knee amputees) are especially unlikely to receive a prosthesis (Davie-Smith et al., 2017; Webster et al., 2012) and older age is associated with a lesser likelihood of obtaining a prosthesis (Mundell et al., 2016b), which correlates with the Medicare population. The data is not as clear for individuals with limb difference, encompassing a wide variety of conditions that require the use of custom orthoses to brace and support the legs, arms, neck and spine.

Because of this low prevalence of limb prostheses use, many amputees use wheelchairs to navigate their homes and perform mobility-related activities of daily living, such as grooming, bathing, and preparing meals. In fact, about 30 to 60 percent of adults exclusively use a wheelchair after lower leg amputation (Miller et al., 2020). In addition, many individuals who use prostheses to ambulate outside of their home augment their mobility with a wheelchair to perform in-home activities when their prostheses are not in use. As such, it is vital that the wheelchairs these individuals use promote maximal independence and function, particularly to perform mobility-related activities of daily living (“MRADLs”) in the home. Adding power seat elevation to wheelchairs is one critical way to meet the needs of this limb loss population, as well as individuals who have orthopedic conditions that require the use of custom fabricated orthoses to be functional in the home.

A power seat elevation system raises and lowers wheelchair users while remaining in a seated position (Waugh, K., & Crane, B., 2013). This vertical movement enables individuals to change their sitting height in a variety of settings and environments, thereby facilitating daily activities and promoting psychosocial benefits (Ding et al., 2008). The advantages of such movements are tremendous; seat elevation improves wheelchair users’ ability to complete activities of daily life, facilitates transfers to other surfaces, allows for eye-to-eye communication, promotes safety, and prevents injury.

In a Georgia Institute of Technology survey of wheelchair users, over 90 percent of respondents indicated they used their seat elevation device “often” or “sometimes” to help with daily activities such as reaching, eating/preparing a meal, bathing, dressing, and toileting (2017). In that same survey, 80 percent of respondents indicated they used seat elevation “often” or “sometimes” during transfers to or from their wheelchairs. Transferring from a wheelchair to another surface—like a bed or toilet—is essential; on average, wheelchair users transfer 15 to 20 times per day (Kim et al., 2015). Transfers from a level or elevated seat surface, which seat elevation permits, requires less lower extremity strength and less extension in the upper extremities, thereby making it much safer and less difficult (Edlich et al., 2003). Beyond these physical benefits of seat elevation are numerous psychological benefits for people with limb loss and limb difference who use wheelchairs in the home.

Finally, seat elevation promotes safety and reduces injury secondary to long-term wheelchair use. Individuals who use wheelchairs are at high risk for developing repetitive stress injuries, but seat elevation can minimize the risk of repetitive stress injuries at the shoulder complex and cervical spine (Sabari et al., 2016). Furthermore, the level, horizontal gaze that seat elevation facilitates improves safety by helping wheelchair users avoid obstacles (Diebo et al., 2016) and reduces pain and injury in the shoulders, neck, and spine caused by constantly looking upward to perform or participate in MRADLs.

Because so many individuals with limb loss and limb difference rely on wheelchairs, with or without the use of prostheses or custom orthoses, it is essential that the wheelchairs they use provide access to the vertical environment in the home to perform or participate in MRADLs. Without such access, individuals living with limb loss and limb difference who rely on wheelchairs will be unable to perform many vital activities of daily life safely and effectively.

O&P Alliance Position on the Proposed NCD for Seat Elevation

As CMS prepares its final NCD for release in May 2023, the O&P Alliance urges the agency to:

On behalf of the Medical Device Manufacturers Association (MDMA), I wish to express our support for the proposed National Coverage Determination that would provide national Medicare coverage for power seat elevation equipment for certain beneficiaries with a Group 3 power wheelchair.

We agree with CMS’s conclusion that seat elevation systems serve a medical purpose in preventing musculoskeletal pain and injuries caused by repetitive transfers between non-level surfaces that are essential for beneficiaries to accomplish various mobility-related activities of daily living (ADLs). We appreciate the agency’s recognition that previous determinations characterizing seat elevation systems as “convenience” or “luxury” items failed to recognize the detrimental physiologic effects of repetitive transfers.

We are concerned that CMS has limited its review and coverage determination for seat elevation systems to the specific indication for use of preventing pain and injuries associated with repetitive weight-bearing transfers. In doing so, CMS appears to have blurred the distinction between benefit category and coverage determinations. The agency also summarily dismissed the request and supporting evidence submitted by the requestor related to the medical benefits of reach and line of sight functions. Furthermore, the position paper from the Rehabilitation Engineering & Assistive Technology Society of North America (RESNA) cited by CMS in the decision memo identifies a number of benefits unrelated to weight bearing transfers that support medical necessity for the technology. As CMS considers coverage of mobility assistive equipment, such as the pending request for power standing systems, we encourage the agency to consider the wide range of adverse clinical impacts associated with long-term seated wheelchair use—including pain from causes other than transfers, as well as impacts on circulation, bone strength, muscle spasticity and skin health. For all assistive technologies, CMS also should carefully consider the health-related benefits associated with functional improvement in a beneficiary’s performance of mobility-related and non-mobility-related ADLs.

We appreciate every opportunity to work with CMS to improve access and quality of life for Medicare beneficiaries.

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First, I want to thank the ITEM Coalition for opening up comments to allow individuals to give their opinion and stance on this important topic. I am an Occupational Therapy master’s student who was overjoyed to hear CMS release its proposed decision to offer Medicare coverage for seat elevation/ standing systems in power wheelchairs. The Medicare program prohibiting coverage for seat elevation and standing system due to thinking it is a “luxury” service for wheelchair users is false. According to Glickman et al., evidence supports weight bearing can help improve joint mobility in hips, knees and ankles and reduce the effect of contractures in children and adults who have neurological conditions (2010). Also, standing can increase muscle strength, bowel and bladder function, participation in activities of daily living (ADL), and psychological well-being. In order to achieve any of these benefits, an individual needs to stand for no less than 30-60 minutes a day. An individual with a disability that does not have a power wheel chair standing system may not be able to stand the required amount of time daily to see benefits without having support from a caregiver(s). Without a power wheel chair standing system, an individual may have decreased independence in their occupations. Standing systems can allow individuals to participate in occupations such as meal preparation and household management by now being able to stand at the stove to cook/reach for ingredients and wash dishes after cooking a meal. Recently, a case study was conducted to explore the effects of power wheelchair standing device usage in children and adults where researchers used the Canadian Occupational Performance Measure (COPM) to look at individuals satisfaction and performance in areas of self-care, leisure and productivity. Three out of 4 participants had a significant increase in performance in the three categories when using the wheelchair standing device (Gohlke & Kenyon, 2022). In conclusion, Medicare covering seat elevation/standing systems allows more individuals to become more independent and ultimately increasing their quality of life.

Thank you for reading,
Erin Taylor, OTS

References:
Glickman, L. B., Geigle, P. R., & Paleg, G. S. (2010). A systematic review of supported standing programs. Journal of Pediatric Rehabilitation Medicine, 3(3), 197–213. https://doi.org/10.3233/prm-2010-0129

Gohlke, J. H., & Kenyon, L. K. (2022). Exploring powered wheelchair standing device use in children and adults: A longitudinal case series. Disability and Rehabilitation: Assistive Technology, 1–13. https://doi.org/10.1080/17483107.2022.2120101

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United Spinal Association appreciates the opportunity to comment on the Centers for Medicare and Medicaid Services’ (CMS) proposed National Coverage Decision (NCD) for seat elevation systems in Complex Rehabilitation Technology (CRT) power wheelchairs.

As a Steering Committee member of the Independence Through Enhancement of Medicare and Medicaid Coalition, United Spinal endorsed the National Coverage Decision Request submitted to CMS in September 2020 a formal “Request for Reconsideration of the Medicare National Coverage Determination [NCD] for Mobility Assistive Equipment [MAE] to Include Seat Elevation Systems and Standing Systems for Group 3 Complex Rehabilitative Power Wheelchairs”, we stated then and we state now that both “power seat elevation systems and power standing systems used in conjunction with a Group 3 power wheelchair (“PWC”) are two systems that can be critical to the health, function, independent living, and well-being of Medicare beneficiaries with mobility impairments as a result of a permanent disability and other clinical needs…..” We reiterate that CMS must follow through on its commitment that a comment period on standing systems will be opened as expeditiously as possible.

United Spinal Association, founded by paralyzed veterans in 1946, is dedicated to enhancing the quality of life of all people living with spinal cord injuries and disorders (SCI/D), paralysis, neurological conditions and other mobility disabilities, including veterans, and providing support and information to loved ones, care providers and professionals. United Spinal represents 5.5 million wheelchair users across the country, has over 60,000 members, 46 chapters, 119 support groups and more than 100 rehabilitation facilities and hospital partners nationwide. Additionally, we work collaboratively with Spinal Cord Injury Model (SCI) System Centers and the Model Systems Knowledge Translation Center that provide innovative research and support in the field of SCI. United Spinal Association is also a VA-accredited veterans service organization (VSO).

We applaud CMS’ recognition that seat elevation systems are primarily medical in nature and reasonable and necessary for beneficiaries who use these systems to perform transfers for the purpose of performing or participating in mobility-related activities of daily living (MRADLs). This concept is supported by a substantial body of clinical research. We urge that the proposed Benefit Category Determination stating that power seat elevation systems are primarily medical in nature and are considered durable medical equipment be finalized. In addition to including coverage for Group 3 power wheelchair seat elevation, United Spinal also appreciates CMS seeking specific comments on power seat elevation equipment on Group 2 power wheelchairs and supports the inclusion of that coverage for all those who need it.

Specifically, CMS must include coverage for Medicare beneficiaries who need seat elevation for the purpose of improving their reach and line of sight to support shoulder, upper spine, and neck integrity while performing or participating in MRADLs. CMS must also provide important clarifications to the proposed NCD, including further detail regarding “weight-bearing transfers,” beneficiaries using patient transfer devices, and the specific criteria for specialty evaluations. United Spinal also requests that CMS review and clarify the specific criteria for specialty evaluations that are called for in the NCD.

In United Spinal’s over 75 years of existence, we are acutely aware of the countless specific needs individual wheelchair users have when transferring from and to their wheelchairs. One element in transfers is universal, all involve weight-bearing in one form or the other. However, as written in the current NCD, the scope and specifics regarding “weight-bearing transfers,” that beneficiaries using transfer devices with or without personal care assistance needs additional definition and clarification.

United Spinal also requests CMS include the critical elements of better health outcomes (not to mention much better safety outcomes) that reach and line of sight provide individuals in performing MRADLs. As you are aware, the need and benefits of a power seat elevation system not only improves transfers but also improves beneficiary access to the vertical environment for reach and line of sight requirements to safely and effectively perform or participate in MRADLs. This is supported in the evidence base, by subject matter expert consensus, patient-centered outcomes data, and is recognized by national disability and medical professional organizations. It is also supported by third-party payers such as the Department of Veterans Affairs, state Medicaid programs, and private payers that currently provide coverage of seat elevation to individuals with mobility impairments. Medicare should adopt the same breadth of coverage as these other payers and not parse its coverage determination.

United Spinal respectfully suggests that a thorough review of the total body of research that we and the vast coalition of clinicians have previously provided CMS, as part of the initial Request for Reconsideration from September 2020, would yield far greater and longer-term health and well-being outcomes for wheelchair users. United Spinal Association also endorses the NCA on seat elevation comments submitted by the ITEM Coalition, the Clinician Task Force and the National Coalition for Assistive and Rehab Technology. United Spinal requests that CMS conduct a comprehensive review of the literature on power seat elevation systems to ascertain the medical benefits of reach and line of sight functions.

United Spinal also requests that the final NCD include coverage of power seat elevation for Medicare beneficiaries who need to use Group 2 CRT power wheelchairs. Clearly, Medicare beneficiaries aged 65 and older are more susceptible to falling. In fact, according to one study, “Falls are the leading cause of injury among adults aged =65 years (older adults) in the United States. In 2018, an estimated 3 million emergency department visits, more than 950,000 hospitalizations or transfers to another facility (e.g., trauma center), and approximately 32,000 deaths resulted from fall-related injuries among older adults.” Moreland B, Kakara R, Henry A. Trends in Nonfatal Falls and Fall-Related Injuries Among Adults Aged =65 Years — United States, 2012–2018. MMWR Morb Mortal Wkly Rep 2020;69:875–881. DOI: https://www.cdc.gov/mmwr/volumes/69/wr/mm6927a5.htm?s_cid=mm6927a5_w. Whether Group 2 wheelchair users have fallen or they are considered at high risk to fall and as a consequence perform their MRADLs in a wheelchair from a seated position, clearly, seat elevation would add a considerable degree of safety as well as improved health outcomes.

Finally, CMS proposes to require that individuals seeking coverage for seat elevation must undergo a “specialty evaluation” by a practitioner with specific training and experience in rehabilitation wheelchair evaluations (the licensed/certified medical professional or LCMP). This is already standard practice for the provision of power wheelchair features on CRT power wheelchairs to wheelchair users, and we support this requirement. CMS already prescribes specific requirements for evaluations to provide beneficiaries with power wheelchair bases and power seating functions such as the tilt and recline feature. We encourage the agency to clarify that the same standards should apply for evaluations of a beneficiary’s need for power seat elevation. This should include the required involvement of an assistive technology professional (ATP) employed by the wheelchair supplier who can provide direct, in-person training and assistance for the beneficiary. CMS should also institute the condition that the LCMP conducting the evaluation does not have a financial relationship with the seat elevation supplier.

The clinician and supplier work together through the evaluation and assessment process to consider the beneficiary’s medical needs, clinical conditions, and other factors that drive the specific technology recommendation. This may include, but is not limited to, the mobility-related activities of daily living in the home environment, functional needs and capabilities, and the technology solutions designed to ameliorate the mobility challenges. In addition, as addressed in the ITEM Coalition’s original Reconsideration Request, the team will identify the least costly, but medically appropriate technology and consider contraindications that would prevent the beneficiary from using certain technologies. This approach provides protection for the beneficiary and Medicare’s expenditures as the clinical and technology decision-making process that occurs is documented in the beneficiary’s medical record.

The clock is ticking on the lives of many Medicare beneficiaries, who’s health and safety could benefit from Medicare covering the cost of seat elevation and standing frame systems. It bears repeating that CMS’s own health equity principles support improved health outcomes according to CMS’ own diversity policy for its employees:

“At CMS, we believe that at the core of our organization are the employees that carry out the Agency’s vision: Advancing health equity, expanding coverage, and improving health outcomes.” https://www.cms.gov/about-cms/careers-cms/diversity-equity-and-inclusion

And if you have engaged with your own Disability Employee Resource Group (Disability ERG) at DERG@cms.hhs.gov, they would also tell you of the need for finalizing this proposed decision on seat elevation for Group 2 and Group 3 power wheelchair users, based on the challenges that the disability community faces every day with access to needed durable medical equipment.

But for access to seat elevation. Think of all the Medicare beneficiaries who have fallen in their homes trying to reach their medication or food in their kitchen cabinets or refrigerators or cook on their stoves to feed themselves or their family members. Think of all the individuals who still suffer and die from not having the right equipment. On standing systems, think of all the muscle contracture surgeries that have occurred that cannot be reversed because a Medicare beneficiary has not been afforded the ability to obtain access to standing systems. Think of all the Medicare beneficiaries who are currently not able to avail themselves of these technologies unless they are ‘lucky’ enough to have the necessary funds. This is America, this should not be the lottery system, medically necessary technologies should be available to Medicare beneficiaries who need it.

And finally, think of all the potential future Medicare beneficiaries, many of whom may be reading these comments now, who may, today, or in the future, be sentenced to a lower quality of life and/or a shorter life through no fault of their own. Think about that. Is that the life you would like to live? Please finalize this proposed decision and provide coverage for Group 2 and Group 3 power wheelchairs for the benefit of all Medicare beneficiaries who rely on critical medical technology to live their lives. We look forward to viewing your upcoming proposed decision on coverage for standing systems as well.

Thank you for considering these comments. Please do not hesitate to contact Alexandra Bennewith, Vice President, Government Relations, United Spinal Association at abennewith@unitedspinal.org or Kent Keyser, Public Policy Fellow at kkeyser@unitedspinal.org.

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March 17, 2023

SUBMITTED ELECTRONICALLY VIA Medicare Coverage Database Portal

The Honorable Chiquita Brooks-LaSure
Administrator
Centers for Medicare and Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

Re: CAG-00461N: Seat Elevation Systems as an Accessory to Power Wheelchairs

Dear Administrator Brooks-LaSure:

Thank you for your proposal and support the Benefit Category Determination and coverage decision. The proposed NCD determines that seat elevation systems in Group 3 power wheelchairs are primarily medical in nature and so fall within the Durable Medical Equipment category. This is the first time Medicare has recognized these systems as DME.

The NCD also proposes to find that these systems are reasonable and necessary for Medicare beneficiaries using Group 3 power wheelchairs when they perform weight-bearing transfers in the home to/from their wheelchair, with or without the use of caregiver assistance or assistive technology, and undergo a specialty evaluation by a practitioner with specific training and experience (e.g., physical and/or occupational therapists) in rehab wheelchair evaluations.

The Spina Bifida Association (SBA) strongly supports the proposed decision, which would dramatically increase access to this critical technology for beneficiaries who spend all or most of their time in a Group 3 chair. This will be a major victory for the disability community and will advance health equity in the Medicare population. SBA is also seeking two important inclusions to the proposed decision – coverage for reach & line of sight, and coverage for Group 2 wheelchair users.

SBA recommends the extension of coverage proposal to improve reach and line of sight to support shoulder, upper spine, and neck integrity. We urge CMS to include people with Spina Bifida (SB) who are Group 3 wheelchair users and would benefit from increased reach and improved line of sight provided through seat elevation in the final NCD. CMS limited its own evidence review to only clinical studies regarding transfers; the agency should conduct a comprehensive evidence search to fully consider other benefits of seat elevation, including reach and line of sight. The evidence base, subject matter expert consensus, and patient-centered outcomes data all support the medical benefits for reach and neck positioning/line of sight in the built environment. The initial NCD Request submitted by ITEM Coalition, of which SBA is a member, cited numerous studies of the benefits of improved reach and line of sight for shoulder, neck, and upper spine function.

Seat elevation supports reduction of musculoskeletal disorders in shoulder, upper spine, and neck by limiting the need to constantly reach over one’s head and look up. It also reduces neck pain and discomfort by improving line of sight, and Improved reach and line of sight through seat elevation makes performance of mobility-related activities of daily living (MRADLs) safer for wheelchair users. Reach and line of sight are critical and necessary to improving wheelchair users’ health, safety within the home, and quality of life and beneficiaries should be able to access seat elevation to address these needs.

SBA supports access to seat elevation for users of Group 2 power wheelchairs. CMS has indicated they are considering inclusion of users of Group 2 power wheelchairs for seat elevation coverage. SBA strongly supports this inclusion.

While the equipment and standards for Group 2 wheelchairs are different from Group 3, people using Group 2 power wheelchairs who need seat elevation should qualify for coverage under Medicare. The Group 2 population typically includes people with certain chronic medical conditions impacting cardiovascular and pulmonary function (e.g., congestive heart failure, osteoarthritis, and COPD), lower extremity Acquired Loss of Limb(s), autoimmune diseases (e.g., Inclusion Body Myositis, Lupus, Myasthenia Gravis, Rheumatoid Arthritis, Scleroderma, etc.), and (Poly)Neuropathies. This differs from the Group 3 power wheelchair user population who have a congenital skeletal deformity, myopathy, or neurological diagnosis.

If their mobility is limited to the point where seat elevation would be reasonable and necessary for their medical needs, they shouldn’t be boxed out just because they don’t fit into the specific diagnoses that fit under the Group 3 coverage criteria. Seat elevation can help Group 2 power wheelchair users safely transfer to/from their power wheelchair and gain access to the vertical environment to perform MRADLs, like toileting, bathing, and grooming. Seat elevation provides a basis for level transfers to reduce upper extremity strain during lateral transfers and lower extremity strain during “sit-to-stand” transfers.

Many Medicare beneficiaries aged 65 and older live alone, are deemed a high fall risk or have fallen while standing or with attempts to stand and subsequently perform their MRADLs from a seated position. If CMS extends coverage for seat elevation to include Group 2 power wheelchairs the minimum height of the seat elevation system must be high enough (at least 6”) for people to safely reach the surfaces and items they need to access within the home to cook, clean, and take care of their hygiene and grooming needs.

SBA would like to see additional clarity on proposed limitations of “weight-bearing transfers.” “Weight-Bearing Transfers”: SBA is seeking clarification on CMS’ proposed definition of “weight-bearing transfers” and beneficiaries that might be excluded from coverage based on this definition. Patient Transfer Devices: SBA is also seeking clarification on whether beneficiaries who use a patient transfer device such as a floor or ceiling-mounted lift to transfer in and out of their wheelchair would qualify for coverage of seat elevation under this proposed NCD. Evaluation Criteria: SBA recommends that the evaluations for seat elevation, including qualifications and criteria for the practitioner conducting the evaluation, be consistent with the current requirements for similar evaluations performed for CRT wheelchair bases and other power seating functions covered by Medicare. SBA calls on CMS to clarify these questions and ensure that all beneficiaries who would benefit from seat elevation are able to access coverage under the final NCD decision.

Once again, we applaud CMS for recognizing the significant clinical evidence and overwhelming public support for covering seat elevation in CRT power wheelchairs and encourage the agency to quickly finalize a coverage decision that ensures all beneficiaries who can benefit from seat elevation are able to access this technology under the Medicare program.

Sincerely,

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March 17, 2023

Centers for Medicare & Medicaid Services

Submitted electronically at https://www.cms.gov/medicare-coverage-database/view/national-submit- public-comment.aspx?DocID=309&commentDocType=nca&fromPage=tracking&

Re: CAG-00461N- Proposed National Coverage Determination for Power Seat Elevation on Power Wheelchairs

To Whom It May Concern:

Miller’s is happy to submit comments on the Centers for Medicare and Medicaid Services’ (CMS’) Proposed Decision Memo on Seat Elevation Systems as an Accessory to Power Wheelchairs (Group 3). I am the President of Miller’s Rental & Sales, a family owned HME (Home Medical Equipment) and CRT (Complex Rehab Technology) company with five Ohio locations in Akron, Canton, Cleveland, Columbus, and Youngstown. We employ over 100 staff members and provide specialized equipment and services to thousands of individuals throughout Ohio. Miller’s has been in business since 1949 and has been one of the leaders in providing specialized custom wheelchairs since the 1970s. We have been providing medical equipment for Medicare beneficiaries since the inception of the Medicare program in the 1960s. Many of our clients are covered by Medicare and related Medicare plans.

Miller’s is uniquely qualified to comment because we have decades of experience providing specialized wheelchairs and complex rehab technology. We provide these services for all age groups and disability types. Further, we have been providing power seat elevation systems in recent years for many of our clients through private funding and through some local insurance plans that are paying for this important technology.

Miller’s supports Medicare coverage of this important seating technology to establish important access for Medicare beneficiaries with disabilities and complex medical needs. Power seat elevation is an important component of a complex rehab power wheelchair that allows people to perform or participate in the essential mobility-related activities of daily living (MRADLs) in his or her home.

The need for and benefits of a power seat elevation system not only improves transfers, but it also improves beneficiary access to the vertical environment for reach and line of sight requirements to safely and effectively engage in one’s MRADLs. This is supported in the research, by subject matter expert consensus, patient-centered outcomes data, and is recognized by national disability and medical professional organizations. It is also supported by third-party payers such as state Medicaid programs, commercial payers, and the Veterans Administration that already provide coverage under their programs. We strongly believe it is time for the Medicare Program, as the single largest health care insurer in the nation, to provide coverage for this enabling technology in the same manner as well.

Miller’s is an active member of NCART and assisted with the drafting of their comments on this proposed coverage decision. We are sharing and supporting some of those comments here:

Request
We recommend that Nationally Covered Indications for Power Seat Elevation Equipment on Power Wheelchairs proposed in Appendix B be revised as follows:

Effective for services performed on or after [Month/XX] [20XX], power seat elevation equipment is reasonable and necessary for individuals using complex rehab power wheelchairs with a medical or functional need for vertical movement to allow the beneficiary to perform or obtain assistance to participate in MRADLs in the home when condition 1, 2, and 3 are met and, for Group 2 complex rehab power wheelchairs condition 4 is met, and for Group 3 and above complex rehab power wheelchairs, condition 4, 5, and/or 6 is met:

1. The beneficiary meets all the coverage criteria for a power wheelchair described in the Power Mobility Device LCD; and
2. A specialty evaluation was performed by a licensed/certified medical professional, such as a physical therapist (PT) or occupational therapist (OT) or practitioner who has specific training in rehabilitation wheelchair evaluations of the beneficiary’s seating and positioning needs. The PT, OT, or practitioner may have no financial relationship with the supplier; and
3. The wheelchair is provided by a supplier that employs a RESNA-certified Assistive Technology Professional (ATP) who specializes in wheelchairs and who has direct, in-person involvement in the wheelchair selection for the beneficiary.
4. The individual performs transfers to/from the power wheelchair while in the home, using their upper extremities and/or their lower extremities. Transfers may be accomplished with or without caregiver assistance and/or the use of any type of assistive equipment (e.g., cane, crutch, walker, sliding /transfer board, transfer assist handles, trapeze, transfer/pivot disk, sit- to-stand device, patient lift/transfer system, etc.).
5. The individual is at high risk for repetitive strain injury or has limited range of reach of the upper extremities, which prohibits performance of or participation in one or more MRADLs from a static seat height due to limited upper extremity strength, limited upper extremity range of motion, deformity, and/or short stature, and
   1. The beneficiary does not have sufficient balance, strength, range of motion, and/or endurance to stand and participate in or perform their MRADLs; and
   2. The beneficiary is able to participate in or perform their MRADLs from a seated position in the home with the provision of a power seat elevation system.
6. The individual has limitations in vision, neck range of motion and/or posture induced neck reflex activity, and cervical hyperextension of the neck:
   1. Prohibits the performance of or participation in one or more MRADLs from a static seat height; or,
   2. Results in the beneficiary losing contact with their alternative drive input device to operate their power wheelchair and/or power seat functions from a static seat height; and,
   3. The beneficiary is able to operate their power wheelchair, and power seat functions to participate in their MRADLs from a seated position in the home with the provision of a power seat elevation system.

We also recommend CMS consider NCART’s recommended revisions to the National Coverage Determination for Mobility Assistive Equipment to support the NCD for Power Seat Elevation Equipment, as originally proposed in the ITEM Coalition’s NCD Request for Reconsideration in September 2020.

Lastly, we strongly recommend CMS work with the DME MACs and stakeholders to take the additional steps required to establish coverage criteria necessitated by the National Coverage Determination for Power Seat Elevation Equipment in the Power Mobility Device and Wheelchair Options/Accessories Local Coverage Determinations (LCDs) and their associated Policy Articles to effectuate this change accordingly.

Further comments supporting these recommendations are provided below.

I. NCA – Seat Elevation Systems as an Accessory to Complex Rehab Power Wheelchairs (Group 3 and above)

We agree with CMS’ proposal to allow power seat elevation equipment on Group 3 power wheelchairs both at initial issue and as a modification to a beneficiary-owned power wheelchair upon implementation of the policy.

We recognize it is CMS’ current policy that Group 4 PWCs have added capabilities that are not needed for use in the home and if provided they will be denied as not reasonable and necessary (CMSa, 2015). However, we contend Group 4 power wheelchairs serve a medical purpose for certain individuals with disabilities, and/or in certain environments of use. Therefore, we request consideration for power seat elevation equipment to be extended to Group 4 PWCs if the base is deemed a necessary upgrade.

We also recognize that CMS has specific criteria for coverage of a Group 5 (pediatric) power wheelchair that must be met for it to be considered a covered benefit (CMSa, 2015). We contend that power seat elevation equipment serves in a special developmental capacity, similar to a seat to floor or standing system (CMSb, 2015), and request CMS to recognize seat elevation systems as an accessory to power wheelchairs that include Group 5 as well.

II. Seat Elevation Systems are Durable Medical Equipment

We agree with and support CMS’s determination that power seat elevation equipment on power wheelchairs falls within the benefit category for durable medical equipment (DME) and are pleased that this enabling technology has been determined to serve a medical purpose. However, we assert that the medical purpose of power seat elevation extends beyond the limited scope of transfers for some Medicare beneficiaries, and as supported by the clinical evidence presented to CMS in the formal NCD Reconsideration Request submitted by the ITEM Coalition in September 2020.

III. Seat Elevation Systems are Reasonable and Necessary if Certain Conditions are Met

As a threshold matter, we agree with and support CMS’s determination that power seat elevation equipment on power wheelchairs should be deemed reasonable and necessary if established conditions are met. We support, in part, the proposed National Coverage Determination language changes detailing these conditions, as outlined in appendices B and C of the proposed decision memo but respectfully request consideration of our recommended changes, as discussed in this letter.

IV. Seat Elevation Systems Serve a Medical Purpose for All Transfers

While we support CMS’ efforts to establish medically necessary criteria for seat elevation systems, we have concerns with the criteria set forth in the NCD with regard to the proposed criteria for “non-level (uneven)” and “weight-bearing” transfers.

1. We are concerned that individuals who perform non-level (uneven) transfers would be precluded from coverage of a seat elevation system even if the safest, or most effective transfer is performed utilizing a downhill, gravity assisted method. We agree with the Paralyzed Veterans of America that the transfer surfaces should be either at equal height or downhill, as uphill transfers are known to increase forces in the upper limb (PVA, 2005), which is supported extensively in the research. We strongly recommend striking the words “non-level (uneven)” from the proposed condition that must be met for

a. Beneficiaries who require a mechanical lift transfer sit on a sling while being transferred to their chair but must have the sling removed to fully complete the execution of the transfer, so they are able to take advantage of the skin protection and/or positioning properties of their wheelchair seat cushion. Remaining in a seated position on the sling throughout the day would be deemed an incomplete transfer, eliminates the medical benefits derived from the wheelchair seat cushion, and places the beneficiary at heightened risk for the development of a pressure injury and secondary medical complications.
b. For individuals with significant trunk weakness, poor balance, and/or postural control challenges as a result of a neurological condition, myopathy, or congenital skeletal deformity it is necessary to change the seat height for beneficiary safety and minimize beneficiary fall risk when removing or placing the sling. For example, the seat may be elevated to one height for a 5-foot-tall caregiver to remove their sling following the transfer to the chair and then elevated to a different height, for a different caregiver who is 6-feet tall to place the sling under the beneficiary at the start of the transfer out of the wheelchair.
c. Once a complete transfer is executed to the chair, and the beneficiary is provided the necessary stability afforded by their wheelchair cushion, back, and postural support components, there is medical benefit for a seat elevation system in maintaining shoulder, spine, and neck integrity for reach and line of sight requirements to perform or participate in their MRADLs.

V. Seat Elevation Systems Serve a Medical Purpose for Safe Reach and MRADLs

In addition to transfers, seat elevation systems serve the medical purpose of reaching in a way that minimizes the risk for pain and injuries while completing one’s MRADLs. In particular, individuals that may not use their upper or lower extremities to transfer could use a seat elevation system to permit adequate range of reach and perform their medically necessary MRADLs. We respectfully request CMS review the peer reviewed research related to the application of power seat elevation systems for reach that were submitted with the original request by the ITEM Coalition in September 2020 and deemed complete in November 2020. Further, we request CMS take into consideration subject matter expert consensus, patient-centered outcomes data, and the numerous comments supporting the use of power seat elevation for the purpose of reaching the vertical environment to allow beneficiaries to perform or participate in their MRADLs submitted during the initial open comment period August 14 – September 15, 2022 as well as the comments on this subject during this comment period.

One of the “other conditions” that limit the beneficiary’s ability to participate in their MRADLs is the height of the surfaces they need to reach in the home. The inability to safely reach items can be ameliorated or compensated for adequately by the addition of a power seat elevation system for those individuals who must perform their MRADLs from their wheelchair in a seated position. For example, a home assessment, as required by the Power Mobility Device Local Coverage Determination (L33789) prior to or at the time of delivery of the power wheelchair, would verify that the beneficiary can adequately utilize the power wheelchair with the seat elevation system in the home, considering the physical layout and surface heights, to significantly improve their ability to perform or obtain assistance to participate in one or more MRADL.

This need extends to individuals who require a mechanical lift to transfer as well. These individuals may benefit from the use of a seat elevation system to reach the vertical environment and perform or participate in their MRADLs in the home once they are seated in their wheelchair with the appropriate cushion, back, and postural support components in place.

In conclusion, Clinicians, consumers, manufacturers, and providers all agree Medicare coverage of this important technology will improve the safety and quality of the life for wheelchair beneficiaries. Miller’s is proud to support CMS’ proposed benefit category decision that recognizes power seat elevation equipment as medically appropriate and necessary.

Thank you for the opportunity to comment. Please contact me at jpm@millers.com for further information or if you have any questions.

Sincerely,

Johnny P. Miller
President

Miller’s Rental & Sales
2023 Romig Rd
Akron, OH 44320
(330) 753 -9600 x12100
jpm@millers.com
www.millers.com

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Thank you for the opportunity to comment on the inclusion of seat elevation systems on group 3 power wheelchairs as a medical device.

I am a clinical professor in the Division of Occupational Therapy, School of Health and Rehabilitation Sciences at The Ohio State University (OSU), the Program Director for the Assistive and Rehabilitative Technology Certificate Program at OSU, and the Director of Rehabilitation Science and Technology in the Assistive Technology Center at The Ohio State University Wexner Medical Center. Prior to working at OSU (2009-current), I ran an assistive technology consulting firm (2006-2009) and worked at the Assistive Technology Unit at the University of Illinois – Chicago (2000-2006). I have a Bachelor of Science Degree in General Engineering with a Bioengineering Option from the University of Illinois Urbana-Champaign (1994) and a Doctor of Philosophy Degree in Bioengineering from the University of Pittsburgh (2001). My comment on the inclusion of seat elevation systems on power wheelchairs as a medical device is based on my over 25 years of experiences as a rehabilitation engineer in clinical practice, an entrepreneur, a researcher, and an educator. Though I currently work at The Ohio State University, these comments are my own, and do not represent the opinions of my employer. In addition, though I am the current president of the Rehabilitation Engineering and Assistive Technology Society of North America (RESNA), and support the comments of RESNA, these comments are my own, and do not represent the opinions of RESNA.

First, I want to thank the Centers for Medicare and Medicaid Services (CMS) for their proposal and support of the Benefit Category Determination and coverage decision. Second, I want to recommend extension of coverage proposal to improve reach & line of sight to support shoulder, upper spine, and neck integrity. Third, I support access to seat elevation for users of Group 2 power wheelchairs. Fourth, I seek clarity on proposed limitations of “weight-bearing transfers.” Finally, I recommend that CMS works with stakeholders to undertake a thorough state of the technology review of power wheelchair bases and power seat elevation, and consider changes to coding, code requirements, and performance requirements for PWCs that can accommodate power seat elevation devices with seat elevation range that exceeds 6 inches, and those that can be combined with other power seating systems. As a former member of the RESNA Assistive Technology Standards Board (ATSB), I fully recognize the importance of wheelchair standards on promoting the functionality and safety of wheelchairs for individuals with mobility impairments. RESNA’s Wheelchair Standards Committee is willing to assist or provide additional advice related to the technology review.

Thank you for the opportunity to comment on the inclusion of seat elevation systems on power wheelchairs as a medical device. My comments is based on current best evidence in the literature, my own experience working with individuals with mobility impairments, and my experience as a researcher in the field of assistive technology.

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March 17, 2023

The Honorable Chiquita Brooks-LaSure
Administrator
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201

Thank you for the opportunity to comment on this proposed National Coverage Determination (NCD) that would expand coverage for power seat elevation equipment on certain power wheelchairs to Medicare members.

Please accept the following comments from Cityblock Health, Inc. and Cityblock Medical Practice, P.A. (Cityblock). Cityblock is a provider organization that partners with health plans to deliver integrated physical, behavioral, and social care to Medicare, Medicaid, dually eligible, and other members living in lower-income neighborhoods that have historically had poor access to health care services. Nearly 80% of our members are persons of color, 85% have two or more chronic conditions, and more than 60% have an identified acute social health need. We submit these comments with a view toward continuing to align the Medicare program with health equity, transparency, and positive member outcomes, particularly for members of underserved communities.

We support CMS’ proposal that there is sufficient evidence to conclude power seat elevation equipment on Group 3 power wheelchairs meets the definition of durable medical equipment (DME), and we support extending that determination to include Group 2 power wheelchairs.

In support of this position, we point to feedback and research shared by:

*The American Medical Association (AMA) May 2020 letter to CMS: “[S]eat elevation facilitates improved transfer biomechanics, enhanced visual orientation and line-of-sight, supports physiological health, safety and well-being, decreases hyperlordotic neck positioning, and reduces the risk of falls and shoulder injuries that are commonly associated with long-term wheelchair use.(1) Additionally, [these] accessories enable individuals with a mobility deficit, sufficient to impair their participation in mobility-related activities of daily living, to do things such as toileting, feeding, dressing, grooming, and bathing in customary locations in the home.(2) As such, these accessories are primarily medical in nature and essential for the health of wheelchair users.”

*The National Council on Disability (NCD) August 2020 letter to CMS: “A seat elevator raises or lowers the seat of the power wheelchair and is used to assist an individual when transferring from the wheelchair to another surface to perform mobility-related activities of daily living (MRADLs), such as a commode, bed, couch, chair, in order to perform or participate in MRADLs such as hygiene, grooming, dressing, and food preparation. The clinical literature indicates that seat elevation can reduce injuries due to falls during transfers and secondary injuries due to multiple transfers over the time of prolonged wheelchair use. Thus, a power seat elevation system fulfills CMS requirements for coverage under the NCD for [mobility assistive equipment (MAE)].”

*The Independence through Enhancement of Medicare and Medicaid (ITEM) Coalition September 2020 letter to CMS, signed by more than 60 organizations: “Seat elevation is critical to MRADL participation and performance, the standard for medical coverage of Medicare mobility equipment. Seat elevation improves transfers and reaching, reduces falls, and reduces or eliminates neck and spine injuries from power wheelchair use.”

We would be pleased to discuss these comments, and appreciate the opportunity to share them.

Sincerely,

Kameron Matthews, MD, JD, FAAFP

Chief Health Officer, Cityblock Health, Inc.
kameron.matthews@cityblock.com

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On behalf of the 5.4 million Americans living with paralysis, I thank the Centers for Medicare and Medicaid Services (CMS) for their proposed decision recognizing the medical necessity of Seat Elevation Systems as an Accessory to Power Wheelchairs (Group 3) for their beneficiaries.

Since 2002, the Christopher & Dana Reeve Foundation has operated the National Paralysis Resource Center (NPRC), which promotes the health and well-being of people living with spinal cord injury, mobility impairment, and paralysis. The NPRC provides the most comprehensive information, resources, and services through our dedicated Information Specialists, a substantial Quality of Life Grants Program, Peer & Family Support Program, and a Military and Veterans Program. The NPRC has provided hundreds of thousands of individuals living with paralysis, their families, and their caregivers with free, life-changing and, often, life-saving information. It is a priority of the Reeve Foundation to ensure that individuals living with spinal cord injury, paralysis, and mobility impairments have access to the care, equipment, resources, and tools necessary to live life to their fullest abilities by participating in their communities and living independently.

Based on our more than 20 years assisting over 120,000 individuals and families living with paralysis, seat elevation is extremely critical for ensuring safety and promoting independence for individuals living with paralysis. Since home health care is often not covered under many insurance plans, a person with paralysis utilizing seat elevation is able to be at home without a caregiver present. It allows users to accomplish safe transfers from a wheelchair to a toilet, bed, shower chair, or other surface and allow individuals to live more independently and perform mobility-related activities of daily living (MRADLs).

Also, as previously noted in our September 2022 comments, individuals utilizing seat elevation can work, cook, dress, and perform daily hygiene tasks often without any other assistance. Not having to “look-up” to speak to someone is also a welcome relief both psychologically and physically. It is hard to overstate how important line of sight can be for a person’s safety and overall mental health.

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As a provider of DME/Complex Rehab for over 40 years I have witnessed first hand the limitations for individuals using power wheelchairs without seat elevation. I would urge anyone involved in making this decision to go home and simulate what it is like to NOT have seat elevation and function in YOUR HOME. Please go into your kitchen and sit on a regular chair placed in front of the stove and try to cook. Try it at the sink and wash the dishes or access the faucets. Go to the refrigerator and reach to the top shelf to retrieve that 1/2 gallon container of liquid. Next go to the bathroom and see how well you do accessing the sink and medicine cabinet. Check out you pantry where your canned foods are stored and see the limitations you now have about where you can place items so you can retrieve them.

We as human being we not "created" to be in a seated posture and function in our world with standing or accessing items at a reasonable height. What a shame to live in a country where we have creativity and product development that can actually make the environment more accessible for those who end up using a mobility device only to be denied it because some people say it is not necessary to perform basic daily activities in the home.

The better experiment for anyone reading this is to actually get a wheelchair and live in it for a day or two so you can really understand the limitations it creates.

Please approve this and give many of our physically challenged individuals the ability to be more independent so they can do more things "on their own" without having to ask, that is assuming there is even someone there to assist them.

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As an Occupational Therapist, a representative of Team Gleason Foundation (a non-profit that actively provides access to power seat elevation), and a member of the ITEM Coalition, I applaud CMS’s proposed recognition of power seat elevation systems as reasonable and medically necessary. I fully support the comments of my colleagues from the ITEM Coalition, and support their clinical, legal, and research-based responses.

Based on my personal experience of providing seat elevators to individuals living with ALS (Amyotrophic Lateral Sclerosis) over the past four years, I offer the following comments and recommendations for expanding the coverage provided through this proposed policy.

As mentioned within the National Coverage Analysis (NCA), the seat elevator is both necessary and reasonable for weight-bearing transfers. While this will provide needed coverage to many beneficiaries, it will not reach all beneficiaries that would benefit from a power seat elevation system. So, I urge CMS to consider revising the proposed determination to expand coverage to ensure the policy addresses all beneficiaries who would benefit from access to power seat elevation systems. Reconsideration is needed for those individuals who primarily use the seat elevator for accomplishing MRADLs from their chair in a safe and timely manner, and clarity is required around weight bearing transfers.

Clarity with Transfers

When considering transfers, the proposed decision memo states that coverage is for individuals that perform “weight bearing transfers to/from the power wheelchair while in the home, using either their upper extremities during a non-level (uneven) sitting transfer and/or their lower extremities during a sit to stand transfer. Transfers may be accomplished with or without caregiver assistance and/or the use of assistive equipment (e.g. sliding board, cane, crutch, walker).” To ensure this policy is not causing unintended consequences, I urge CMS to reconsider this requirement and ensure that it encompasses all beneficiaries that will benefit from a power seat elevator, regardless of transfer modality.

The clients I work with have a progressive diagnosis, and the type of transfer they utilize will change over time or in relation to the caregiver present, and I do not want the wording of this coverage determination to do either of the following:

- Deny seat elevation for those that need a patient lift for transfers some or all the time
- Deny patient lifts for individuals who have been provided a power seat elevator previously

When I consider a client’s transfer, several things are evaluated: the client’s performance skills, the environment, where they are transferring to/from, and the caregiver’s performance skills if this is an assisted or dependent transfer. Numerous combinations arise, and different situations may warrant different transfer methods. In the morning, when an individual is feeling their best, an assisted stand pivot transfer may be the best option, but at the end of the day, when they are fatigued and only accompanied by their spouse, the use of a patient lift may be the best option.

As mentioned above, my concern is that individuals who require multiple transfer modalities, including a patient lift or other assistive technologies not specifically mentioned, may be denied seat elevation.

More importantly, as ALS progresses, a beneficiary may need to begin using a patient lift, as their ability to complete transfer in another style diminishes. I am concerned that with the above language, it is possible to interpret this policy as precluding the use of a patient lift prior to or after receiving a seat elevator.

My clinical experience over the past 4 years of working with individuals living with ALS has provided evidence that a seat elevator does make transfer, even with a patient lift, easier as it can decrease the amount of time, minimize effort, and aid the caregiver in sling management by minimizing the need to bend over. So, I urge CMS to clarify this portion of the policy to ensure the current wording does not preclude a beneficiary from obtaining a power seat elevator because of their transfer modality.

Accomplishing MRADLs from the Chair

As background, in the Local Coverage Determination for Power Mobility Devices (L33789), CMS notes that the “Use of power wheelchair will significantly improve the beneficiary’s ability to participate in MRADLs” as a requirement for coverage of a power wheelchair. CMS defines mobility-related activities of daily living as things “such as toileting, feeding, dressing, grooming, and bathing in customary locations in the home.”

Furthermore, CMS defines a mobility limitation as something that:

1) “Prevents the beneficiary entirely from accomplishing an MRADL entirely, or
2) Places the beneficiary at reasonably determined heightened risk of morbidity or mortality secondary to the attempts to perform an MRADL, or
3)Prevents the beneficiary from completing an MRADL within a reasonable time frame.”

Using the above coverage criteria for power wheelchairs as a guide, I am confused by the narrow focus of the national coverage analysis for seat elevation. According to CMS guidelines, as referenced above, CMS understands that a power wheelchair supports both mobility and function, and specifically mentions several functions that are considered reasonable and medically necessary. Yet, this decision summary does not consider these tasks when determining if seat elevation is reasonable and necessary for a beneficiary. Instead, the NCA mentions a July 26, 2006, determination that states that the iBOT 4000 Mobility System was not primarily medical as the reason for not reviewing these technologies for reach and line of sight. I urge CMS to reconsider this decision, as the iBOT determination was based on a different device and on research that is over sixteen years old.

Reach and line of sight are reasonable and medically necessary. Reach is required to perform numerous MRADLs listed by CMS, including feeding, dressing, and grooming. Furthermore, attempting to complete these MRADLs from a seated position may be impossible for some beneficiaries to complete independently. Specifically, individuals unable to elevate or abduct to or above 60 degrees at the shoulder. These individuals will have difficulty or be unable to reach a sink for hygiene, access clothes hanging in a closet in preparation for dressing, reach items in a cabinet, or cook a meal on a stove top. Conversely, if the same beneficiary had a seat elevator and was able to adjust their height in preparation for the MRADL, the beneficiary will be able to extend at the elbow or abduct at the shoulder under 60 degrees, making it possible and easier for them to complete the MRADL independently.

Additionally, as noted in the NCA, “The mechanism of injury to cause shoulder pain in the power wheelchair user may include previous propulsion of a manual chair, excessive use of the upper extremities in order to perform activities of daily living...” Having to elevate or abduct at the shoulder from a seated position for every MRADL that is typically done in a standing position and for sustained amounts of time, poses a medical risk to the beneficiary.

In collecting feedback from clients over the past four years, Team Gleason has received numerous examples of how a seat elevator assists in and makes medically necessary MRADLs possible. Take the following quotes as an example:

“The seat elevator has helped give my husband some form of independence during this terrible journey where everything is being stripped away from him. It allows him to reach things for himself that he otherwise could not. It allows him to see things from another level and be more a part of our lives and daily activities.” (C.H.)

“I found being able to reach our higher cabinet shelves absolutely freeing. Having a refrigerator with the freezer on the bottom prevented me from reaching the top 2 shelves. With the elevator no more calling out, ‘honey can you get...’! And more important is no more waiting for someone to return home or come into the house to get things for me. The elevator has also made meal preparation possible. Without the elevator I didn't even attempt to cook. […] I have neck problems and looking up for any length of time is painful. Having a pub style kitchen table made it painful and difficult to be part of the conversation. The elevator has given me not only pain free conversation but also a feeling of more connection of being a real part of the group.” (M.C.)

“The elevator allows him to get himself lower or higher in order to do activities. As only ALS families know, the most common of abilities, like those mentioned, become major wins when you can still do them. The elevator allows him to still do basic chores like putting dishes away, getting food and ice out of the freezer, wood off of the wood pile, and getting his own clothes out of the closet. These tasks literally make him feel just a little better, more useful, independent, and grateful for the ability to do them today. When my husband got the chair with the elevator, the first thing he did was raise himself up to eye level to the rest of us who were all standing in the kitchen. With tears in his eyes he said, "I am so thankful to see your face at eye level, I didn't think I would ever be able to do that again." The impact of literally anything that makes life more normal and easier and allows those with ALS to be as independent as possible is more valuable than anyone who is not part of an ALS family can possibly understand.” (W. K.)

“The seat elevator allows me to hold on to some independence a while longer. It's amazing the number of routine tasks I can accomplish with the extra height: store and reach things on high shelves, utilize countertops more easily, reach water faucets, operate appliances, look at myself in the mirror, look out my windows.” (S. P.)

Evidence-Based Practice is a combination of three components: research, patient values, and clinical expertise. With that I posit that it is evidence-based best practice to use a seat elevator for MRADLs and in combination with all styles of weight bearing and non-weight bearing transfers, and I urge CMS to expand coverage to beneficiaries who will use seat elevators for transfers or the completion of MRADLs. Thank you for the opportunity to comment and thank you once again for the current proposed coverage and for your consideration of an expanded policy that will reach more beneficiaries who can benefit from power seat elevation.

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All Wheels Up appreciates CMS's proposal and support for the Benefit Category Determination and coverage decision. As part of the ITEM Coalition All wheels Up supports all ITEM's comments

Seat elevation provides Group 3 power wheelchair users the opportunity to increase participation and independence with valued daily activities. That may include reaching into closets and cabinets or sinks and transfer surfaces during ADL, elevating while navigating the community to increase safety by being able to see and be seen and/or elevating to allow for participation in school, social or valued cultural activities while at standing level with peers.
These examples only scratch the surface of the ways seat elevation impact the lives of wheelchair users and their dependence on others. It is not a luxury or accessory feature.

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Chiquita Brooks-LaSure
Administrator
Centers for Medicare & Medicaid Services
U.S. Department of Health & Human Services
7500 Security Boulevard
Baltimore, MD 21244

RE: Proposed National Coverage Determination for Power Seat Elevation Equipment on Power Wheelchairs

Dear Administrator Brooks-LaSure:

On behalf of Craig Hospital in Colorado, I appreciate the opportunity to respond to the “Proposed National Coverage Determination for Power Seat Elevation Equipment on Power Wheelchairs.” We are pleased to see the recognition of the need for this type of equipment for people with significant disabilities to allow for more independent living and mobility. While we are very appreciative of this move forward, we do have some comments for further consideration of the proposal.

Craig Hospital is a hospital specializing in the acute and life-long care of patients who have sustained a traumatic or acquired spinal cord injury (SCI) and/or brain injury (ABI). Our hospital admits the most severe and medically complex patients with these diagnoses, throughout the continuum of care, encompassing acute medical services, rehabilitation and long-term health management and aging with disability. Our services are dedicated to the complex needs of patients with SCI and ABI. We align with the Patient Centered Medical Home (PCMH) model which suggests the best outcomes occur when patients a) cohorted by specialty, b) are provided care across the continuum, and c) receive care under one (figurative or literal) ‘home.’

As a provider who works with the patients directly impacted by this new determination every day, we would like to recommend some suggestions to benefit the disability community. These changes will go a long way to help people that require these wheelchairs to be more independent, and safe in their homes and daily activities, directly compensating for impairment or injury. Below are our suggestions and concerns for the proposed new determinations for power seat elevation equipment on power wheelchairs.

1. We fully agree with transfers as a criteria, including assisted or independent transfers; but we have additional questions and offer some alterations to the definition -

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I have been in the DME field for over 20yrs. I am an ATP, CCM and RRT. Throughout the years I have been very involved with the ALS community and have seen many other patients that could benefit from a seat elevator. Unfortunately, I have seen patients get injured and/or not able to perform their MRADLS due to not having this feature on their power chair. I want to thank CMS for recognizing power seat elevation systems as medical in nature, seeing the need for these and understanding that they are reasonable and necessary. I strongly support the coverage for the systems to be able to provide to patient that qualify for the systems. Patients that are afforded this system will be able to perform weight bearing transfers when there are uneven surfaces in the home. With the system, the patient will be able to perform these actions without the need of assistance from a caregiver.

I completely agree that the systems are a critical component to use when transferring and support the proposed CMS criteria. I am concerned however that CMS will only allow for this benefit for "un-even" surfaces. I feel that all transfers are weight bearing and even on "even" surfaces that the elevation system would still be beneficial. So, please remove that "un-even" wording from the criteria. Also, I believe that the system are also useful even with caregiver assistance. It provides a safer way to transfer with assistance. So, please do not limit the systems to just patients that can transfer without a caregiver.

With all of that being said, I encourage CMS to approve seat elevating systems not only for weight bearing transfers on both even and un-even surfaces, with and without care giver assistance but also for patient that have the need to perform ADLS that have different level surfaces. Let's not forget about the need to access the freezer, change the thermostat, access the top of a kitchen counter, safely remove a hot pot off a stove, and pull a fire alarm. The need is there!

Lastly, please be sure that the proper professional are needed to evaluate the need for the systems. CMS needs to make sure that not only MD's, PT's and OT's are involved, but also ATP's be a part of this process to assure that the proper equipment is being provided. I also would encourage that CMS not just limit the systems to GRP 3 chairs, but also consider for GRP 2 also.

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The Independence Through Enhancement of Medicare and Medicaid (ITEM) Coalition is pleased to submit these comments on the Centers for Medicare and Medicaid Services’ (CMS) proposed National Coverage Decision (NCD) for seat elevation systems in Complex Rehabilitation Technology (CRT) power wheelchairs. As you know, the ITEM Coalition has long advocated for coverage of these systems as well as power standing systems under Medicare, including through the submission of a formal NCD Reconsideration Request submitted in September 2020.

We applaud CMS for proposing to recognize seat elevation systems as primarily medical in nature and reasonable and necessary for beneficiaries who qualify for this benefit. While we strongly support Medicare coverage of seat elevation as a DME benefit, we offer these comments in response to the proposed NCD and urge CMS to consider revising its decision as noted below to ensure that all Medicare beneficiaries who need access to power seat elevation systems will receive coverage for them.

The ITEM Coalition is comprised of nearly 100 national organizations that seek to improve access to and coverage of assistive devices and technologies that enhance the function of people with disabilities and chronic conditions of all ages. We believe that CMS has not kept pace with the needs of Medicare beneficiaries in terms of coverage of durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS). It is astounding that not one commenter opposed seat elevation coverage out of more than 3,600 individuals and organizations that submitted public comments during the first public comment period. The ITEM Coalition believes this highly suggests that seat elevation coverage should have been available to Medicare beneficiaries with mobility impairments many years ago. This is not the only antiquated policy that CMS retains in this area. For instance, the ITEM Coalition believes the “in the home” restriction for durable medical equipment is a relic of the past and confines beneficiaries unnecessarily to mobility devices that are for use only in the home, without regard to access outside the home and in the community. This is a health equity issue of the highest order.

As you know, the ITEM Coalition submitted in September 2020 a joint NCD Reconsideration Request to cover both seat elevation and standing systems in CRT power wheelchairs. The value of being able to stand, bear weight on the lower limbs, and allow gravity to aid in metabolic functions is well established. Despite the fact that CMS accepted and deemed “complete” this joint request in November 2020, the agency bifurcated the NCD Reconsideration Request for seat elevation and standing systems into two separate NCDs. While the seat elevation NCD proceeds with this comment period, there is still no publicly available timeline for the opening of the NCD Request for coverage of standing systems in CRT power wheelchairs, a critical function that would highly complement seat elevation coverage and address another critical need of Medicare beneficiaries with mobility disabilities. We urge CMS is the strongest terms possible to open a National Coverage Analysis (NCA) for standing systems in CRT power wheelchairs at its earliest opportunity.

***Summary of ITEM Coalition Recommendations:***

As CMS prepares its final National Coverage Determination for release in May 2023, the ITEM Coalition urges the agency to:

1. Finalize the proposed Benefit Category Determination holding that power seat elevation systems are primarily medical in nature and are considered durable medical equipment under the Medicare benefit; and finalize the proposed coverage determination holding that these systems are reasonable and necessary for Medicare beneficiaries who use Group 3 CRT power wheelchairs in order to perform transfers for the purpose of performing or participating in mobility related activities of daily living (MRADLs);

2. Include coverage for Medicare beneficiaries who need seat elevation to improve their reach and line of sight to support shoulder, upper spine, and neck integrity while performing or participating in MRADLs;

3. Include coverage of seat elevation for Medicare beneficiaries who use Group 2 CRT power wheelchairs in the final NCD; and

4. Provide important clarifications to the proposed NCD, including further detail regarding “weight-bearing transfers,” beneficiaries using patient transfer devices, and the specific criteria for specialty evaluations.

The ITEM Coalition strongly supports the proposed determination, with the revisions and inclusions noted below, in order to ensure that all beneficiaries who would receive a medical benefit from seat elevation are able to access coverage under the finalized NCD, as well as ensuing local coverage, coding, and payment decisions.

***ITEM Coalition Support for Proposed BCD and Coverage Proposal***

The ITEM Coalition strongly supports CMS’s decision to consider seat elevation as primarily medical in nature and, therefore, a covered durable medical equipment benefit under the Medicare program. CMS’s previous decision in 2005 deemed these critical features “convenience items” and referred to them in subsequent years as “luxury” items. The ITEM Coalition has taken strong issue with this view, and we are grateful that CMS has finally recognized the medical nature of seat elevation systems in CRT power wheelchairs. We hope this change in perspective signals a sea change in the way CMS meets the needs of Medicare beneficiaries with mobility impairments with respect to access to assistive devices and technologies.

We also strongly support the proposed decision that seat elevation is reasonable and necessary for Medicare beneficiaries with mobility impairments who need seat elevation to perform weight-bearing transfers and aid in the performance of MRADLs, with or without assistance from another person. The evidence base detailed in our NCD Request for Reconsideration clearly establishes that seat elevation has a material impact on the ability to perform MRADLs safely and efficiently while reducing the incidence of secondary injury. CMS laid out much of the evidence base for seat elevation in its proposed decision memo, but the agency confined its inquiry to transfers from one surface to another. The proposed decision seemed to ignore the substantial evidence ITEM Coalition put forth in the original NCD Reconsideration Request to cover seat elevation for the purposes of improving reach and line of sight for the purpose of performing MRADLs while limiting secondary injury.

As pleased as the ITEM Coalition is with the proposed decision, we believe the medical purpose of power seat elevation extends beyond the limited scope of transfers for some Medicare beneficiaries. We question why seat elevation is determined to be primarily medical in nature only to the extent that it facilitates transfers. Frankly, this is an extraordinarily narrow reading of the value of seat elevation for individuals with mobility impairments and is out of sync with other NCDs which typically determine whether an item or service fits within an existing Medicare benefit category and is reasonable and necessary for certain beneficiaries. The Local Coverage Determination (LCD) process usually teases out the specific coverage criteria and which beneficiaries can benefit from coverage.

The need for and benefits of a power seat elevation system not only improves transfers, but it also improves beneficiary access to the vertical environment for reach and line of sight requirements to safely and effectively perform or participate in MRADLs. This is supported in the evidence base, by subject matter expert consensus, patient-centered outcomes data, and is recognized by national disability and medical professional organizations. It is also supported by third-party payers such as the Veterans Administration, state Medicaid programs, and private payers that currently provide coverage of seat elevation to individuals with mobility impairments. Medicare should adopt the same breadth of coverage as these other payers and not parse its coverage determination through a narrow construct.

***The ITEM Coalition Recommends Extension of Coverage Proposal to Include Reach and Line of Sight to Support Shoulder, Upper Spine, and Neck Integrity***

We commend CMS for recognizing the medical benefits of power seat elevation systems to assist beneficiaries with performing safer, more effective transfers. However, we are concerned that the agency has not appropriately considered the significant clinical evidence demonstrating the benefits of these systems for supporting beneficiaries’ reach and line of sight, functions which are not only critical for the performance of MRADLs, but have clear implications for wheelchair users’ health, particularly shoulder, upper spine, and neck integrity. We strongly urge CMS to ensure that the final NCD for power seat elevation systems includes coverage for reach and line of sight as well as transfers.

CMS explicitly states that the agency did not conduct a full evidence review for power seat elevation; instead, the agency did not even consider evidence supporting the benefits of these systems for improving reach and line of sight, despite significant evidence submitted by the ITEM Coalition in the NCD Reconsideration Request. CMS developed an Evidence Question that only considers how transfers may be supported by seat elevation (i.e., “Is the evidence sufficient to demonstrate that power seat elevation equipment associated with a power wheelchair can improve the mobility limitation(s) related to wheelchair transfers that may constrain certain beneficiaries as they attempt to accomplish their MRADLs in customary locations in the home?”)

The agency appears to justify this narrow inquiry by relying on the apparent limits of the Benefit Category Determination, which itself does not provide justification for why the functions of reach and line of sight were excluded from consideration. However, it is clear that CMS intends to render a BCD decision finding that power seat elevation systems do fall within the DMEPOS benefit, because they have been found to be primarily and customarily used to serve a medical purpose. Once this determination has been made with respect to the technology itself, we do not believe the agency can or should limit its review of the benefits of that technology artificially when conducting a “reasonable and necessary” analysis. The coverage criteria should follow the evidence base and there is ample evidence that seat elevation in power wheelchairs is reasonable and necessary for transfers, reach, and line of sight to improve performance of and participation in MRADLs.

Over the course of more than three years of focused discussions with the agency regarding this coverage effort, the ITEM Coalition has consistently been told that the BCD determination and the coverage determination would be treated as separate and distinct inquiries, both of which must be resolved in an affirmative matter to result in coverage for Medicare beneficiaries. Thus, we believe it is inappropriate to limit the evidence review when conducting the separate reasonable and necessary analysis and preclude even consideration of significant medical evidence supporting the benefits of enhanced reach and line of sight in order to perform MRADLs in the home.

Further, the proposed decision memo states that the agency has previously determined that seat elevation was not primarily medical in nature, referencing a BCD for the Independence iBOT Mobility System TM that is nearly 20 years old. We take serious issue with CMS’s reliance on this outdated BCD as a starting point in their analysis of current coverage of seat elevation. First, the original technology assessment conducted during the iBOT National Coverage Analysis specifically limited the evidence search to evidence related to the iBOT system, not the functions of reach and line of sight needed by wheelchair users. This targeted evidence search clearly omitted any studies examining an actual power seat elevation system that was not tied to the iBOT. Additionally, the iBOT NCA focused on a combined seat elevation and balance function that operated entirely differently than the power seat elevation systems within the scope of the current analysis.

The iBOT included both a seat elevator and allowed the seated user to elevate further to standing height through a sophisticated, gyroscopically controlled balance function, where the cluster of four wheels elevated further and balanced on two wheels only. The final iBOT NCD covered the device as a power wheelchair, denied coverage for the balance feature, and assigned a non-covered HCPCS code (E-2300) to the seat elevation feature, consistent with CMS’s longstanding treatment of seat elevation technology. To use a 17-year-old NCD on such a unique mobility device as the starting point for coverage of seat elevation is misplaced and largely ignores the last 17 years of medical research when considering the needs of Medicare beneficiaries today.

We see no reason why CMS should not conduct a comprehensive literature review on power seat elevation systems to examine the medical nature of reach and line of sight functions. Without such a review, the agency is jettisoning significant medical evidence and would propose to “lock in” a coverage policy that bars beneficiaries from accessing technology they need to be healthier, more functional, and more independent – technology that we believe should clearly be covered under Medicare’s rules and regulations.

The initial NCD Reconsideration Request submitted by the ITEM Coalition included a comprehensive review of the medical evidence for reach and line of sight, and our partners at the Clinician Task Force have also submitted additional evidence relating to these functions during the current and prior comment periods. We urge CMS to conduct a similarly comprehensive evidence review and make an evidence-based determination to include coverage for reach and line of sight in the final NCD to improve the performance of MRADLs while limiting fall risk and other injuries of the neck, shoulders, and spine as a result of long-term power wheelchair use.

We encourage the agency to closely review the comprehensive submissions from both the Clinician Task Force and NCART, two national non-profit organizations with extensive knowledge on seating and positioning in mobility devices, which detail the specific evidence base supporting the medical benefits of reach and line of sight through power seat elevation. The ITEM Coalition offers here a summary of some key studies that support our position. All studies are cited more extensively in the Clinician Task Force’s comments, and we incorporate them here by reference.

The proposed decision memo rests coverage of seat elevation systems for transfers largely on the fact, supported by the evidence base, that transfers without seat elevation can lead to shoulder pain and injuries. However, because the agency artificially limited its own evidence review to transfers only, CMS does not consider the evidence that the static height of power wheelchairs without seat elevation leads to similar shoulder, upper extremity, and neck pain and injury when beneficiaries are forced to constantly reach far overheard to conduct everyday activities, or in Medicare parlance, MRADLs. For example, Sabari, et. al., found a significant difference in the active range of motion required when subjects were seated in a wheelchair at the standard height both with and without seat elevation. Users who were able to access an elevated seat height were able to significantly decrease the average shoulder abduction needed to complete daily tasks. As detailed in a 1997 NIOSH study (Bernard), repeated or sustained abduction or flexion of over 60 degrees contributes to tendonitis and other musculoskeletal disorders in the shoulder; coverage of seat elevation would significantly lessen the risk of these issues.

Further, beneficiaries who can access seat elevation receive notable medical benefits from the improved line of sight that seat elevation can offer. Sabari, et. al., also found that with power seat elevation, wheelchair users could reduce their average cervical extension by nearly 10 degrees. Repetitive cervical extension can lead to pain and injury; Kirby, et. al., found that power wheelchair users report approximately 15% greater neck pain than the general population. The use of seat elevation also helps users more safely navigate their environment in the home, lessening the risk of collisions with obstacles that can lead to falls or other injuries.

Simply put, power wheelchair users should be able to access coverage for seat elevation systems to receive the full range of medical benefits that the evidence base justifies. CMS’ final decision should not artificially limit coverage only for the performance of transfers, which could leave out beneficiaries who may not be able to participate in transfers directly but seriously need seat elevation for the improved reach and line of sight these systems can provide. We urge CMS to conduct a comprehensive evidence review of all the medical benefits of seat elevation, and finalize a coverage policy that will ensure Medicare beneficiaries who have a demonstrated medical need for these systems can access coverage.

***The ITEM Coalition Recommends Inclusion of Seat Elevation Coverage for Users of Group 2 CRT Power Wheelchairs***

The ITEM Coalition acknowledged in its original NCD Request for Reconsideration that power seat elevation systems “provide benefits to a broad range of PWC users” (page 21 of NCD Request) but confined its coverage request to Group 3 CRT power wheelchair users only. This targeted request focused on the subpopulation of Medicare beneficiaries who have a permanent disability and full-time need for a Group 3 power wheelchair, a group that we viewed as desperate for seat elevation coverage. This population of users typically has more extensive needs related to performance of or participation in routine MRADLs.

We are grateful to CMS for recognizing in the proposed decision that Medicare beneficiaries who use Group 2 CRT power wheelchairs may also benefit from seat elevation to assist in the performance of MRADLs, particularly through transfers from one surface to another. Specifically, CMS asked whether seat elevation in Group 2 CRT power wheelchairs primarily and customarily serve a medical purpose and thus also fall within the DME benefit category.

The ITEM Coalition strongly supports coverage of power seat elevation for Medicare beneficiaries in need of Group 2 CRT power wheelchairs. In fact, the benefit category determination analysis of the proposed NCD decision and the evidence base is just as applicable to Group 2 power wheelchair users as it is to Group 3 power wheelchair users. There is no principled reason to grant seat elevation coverage to one group of beneficiaries and not the other. CMS’s question as to coverage of seat elevation for Group 2 CRT users is highly device-focused rather than patient-centric. Medicare’s current LCD for Mobility Assistive Equipment (MAE) restricts coverage of Group 3 power wheelchairs to beneficiaries with a mobility limitation that is due to a neurological condition, myopathy, or congenital skeletal deformity. Beneficiaries who do not have these specific diagnoses will not have access to seat elevation unless CMS includes seat elevation coverage for users of Group 2 CRT power wheelchairs in its final NCD. Rather than employing a diagnostic approach, CMS should consider use of a functional test that assesses each patient based on their medical and functional needs, not based on the origin or diagnosis that caused their mobility impairment.

Group 2 power wheelchair users include beneficiaries with a wide variety of conditions that cause significant mobility deficits and limitations on the ability to perform or participate in MRADLs. For instance, beneficiaries who use Group 2 PWCs include individuals with limb loss and limb difference, cardio-pulmonary disorders, COPD, Myositis, Lupus, Myasthenia Gravis, Polyneuropathy, Rheumatoid Arthritis, Scleroderma, and advanced stages of one or more chronic medical conditions. Coverage of seat elevation for this patient population would help many of them perform sit-to-stand/stand pivot, or lateral transfers when participating in MRADLs. As little as six inches or more of seat elevation for Group 2 PWCs could make all the difference in the ability of these beneficiaries to perform transfers safely with less risk of falls or other injuries.

For Medicare beneficiaries who are deemed a high fall risk or have fallen when attempting to stand or while in a standing position during a transfer, the seat elevation system is particularly important because it improves transfer biomechanics, safety, and independence (Schiappa et al., 2019), and may reduce the number of fatal and non-fatal falls for individuals 65 or older.

Beneficiaries with limb loss who use Group 2 power wheelchairs may or may not be able to wear prosthetic limbs. In situations where a beneficiary is not able to perform a stand pivot or sit-to-stand transfer due to limb loss, seat elevation becomes all the more important to their ability to perform MRADLs by enabling a level or downward transfer from their wheelchair. These beneficiaries are at the same risk as Group 3 users for shoulder, neck and back pain and injury due to the need rely on their upper extremities during lateral transfers and reach to perform many MRADLs in the home.

Limited vision is also a prevalent condition in the Medicare population. When performing or participating in MRADLs, vision correction such as eyeglasses may not allow the individual to see and read labels, thermostats, dials on cooking and cleaning appliances, and many other scenarios from a seated position without an accurate line of sight. Beneficiaries who use a power wheelchair as their only means of mobility within their home may benefit from use of a seat elevation system to enhance visual orientation, line of sight, and safety (Schiappa et al., 2019). Based on the evidence, whether the beneficiary is in a Group 3 or a Group 2 CRT power wheelchair is largely immaterial for purposes of determining the medical need for seat elevation.

The ITEM Coalition, therefore, strongly recommends that CMS include coverage for seat elevation for people who have a medical need for a Group 2 CRT power wheelchair to safely transfer in order to perform or participate in MRADLs in the home. This would also allow people who have a medical need for a Group 2 power wheelchair to safely reach overhead and interact with the surfaces and items they need to access in the home to cook, clean, and take care of their hygiene and grooming needs (i.e., perform MRADLs).

To ensure that beneficiaries have appropriate access to the benefits of seat elevation, this final NCD must be followed by the development of a more granular LCD to detail which Medicare beneficiaries will gain access to this technology. Of course, CMS and its contractors must also determine a reasonable HCPCS coding structure and payment levels that reflect the complexity and robustness of various seat elevation systems. Given the different patient populations and seat elevation technologies that serve the Group 2 and Group 3 Medicare beneficiary populations, different HCPCS codes and descriptors will need to be developed for each category of seat elevation technology. There may also be a differential in fee schedule amounts for these systems from one patient population to another, in order to ensure that beneficiaries have access to these covered benefits.

Finally, although the Medicare program does not currently cover Group 4 and Group 5 (pediatric) CRT power wheelchairs, CMS’s final coverage policy on seat elevation should not compromise the ability of users of these technologies to work with other payers to obtain reasonable access to them. The ITEM Coalition stands ready to work with CMS and other stakeholders to develop specific coverage, coding, and reimbursement policies to effectuate seat elevation coverage among Group 2 and Group 3 power wheelchair users.

***The ITEM Coalition Seeks Clarification on the Proposed NCD***

The ITEM Coalition identified several questions arising from the text of the proposed NCD, on which we seek clarification in the final decision. We are concerned that if these issues are not clarified, ambiguities could be left for resolution by the Medicare Administrative Contractors and future LCDs, which could result in coverage being restricted or otherwise hampered in a manner that the final NCD does not intend.

1. Clarification on the meaning of “weight bearing transfers.”

The proposed decision memo states that power seat elevation can be found to be reasonable and necessary for beneficiaries who perform “weight bearing transfers” to and from their power wheelchair within the home. The coverage criteria states that this can include the use of upper extremities for non-level sitting transfers and/or the use of lower extremities during a sit-to-stand transfer and can be supported with or without caregiver assistance. However, the decision memo does not further elaborate on the intended meaning and any limitations included in the term “weight bearing transfers.”

We request that CMS clarify that this term is not intended to exclude certain beneficiaries from accessing seat elevation technology, particularly those that perform dependent transfers. All transfers to and from a wheelchair require weight to be borne somewhere, so in a sense, all transfers are “weight-bearing,” but we question whether the agency intended to prohibit coverage of seat elevation for those wheelchair users who cannot assist with transfers themselves and thus rely on significant caregiver assistance. These beneficiaries could certainly still derive a medical benefit from power seat elevation to perform MRADLs, the standard of coverage for mobility devices under the Medicare program. They could also derive a medical benefit from the ability to rise to a higher plane to provide level or downward transfers which could prolong the ability of caregivers to help beneficiaries facilitate safe transfers without injury.

We encourage CMS to clarify its intended interpretation of this coverage criterion in the final decision memo to include all individuals who would benefit from seat elevation systems for the performance of transfers.

2. Clarification on treatment of beneficiaries who use patient transfer devices.

CMS also states in the proposed decision memo that transfers may be completed with or without the use of assistive equipment, and provides several examples including sliding boards, canes, crutches, and walkers but does not provide an exhaustive list. We question whether this criterion is intended to limit coverage for certain beneficiaries that use more advanced assistive technology, particularly patient transfer devices that may be mounted to the ceiling or floor. Many wheelchair users utilize such devices for transferring from their bed to wheelchair and vice-versa, and as with those who rely on caregivers for dependent transfers, would still benefit significantly from seat elevation to perform MRADLs in the home. The seat elevation function would also be critical when the beneficiary must transfer to another surface in their home that is not located at the site of the mounted mechanical lift.

We encourage CMS to clarify that patient transfer devices such as mounted lifts are included in the intended definition of “assistive technology” used in the proposed decision memo and that the use of such devices should not preclude a beneficiary from otherwise qualifying for coverage of seat elevation under the finalized NCD.

3. Clarification of criteria for specialty evaluations.

Finally, CMS proposes to require that individuals seeking coverage for seat elevation must undergo a “specialty evaluation” by a practitioner with specific training and experience in rehabilitation wheelchair evaluations (the licensed/certified medical professional or LCMP). This is already standard practice for the provision of power wheelchair features on CRT power wheelchairs to wheelchair users, and we support this requirement. CMS already prescribes specific requirements for evaluations to provide beneficiaries with power wheelchair bases and power seating functions such as the tilt and recline feature. We encourage the agency to clarify that the same standards should apply for evaluations of a beneficiary’s need for power seat elevation. This should include the required involvement of an assistive technology professional (ATP) employed by the wheelchair supplier who can provide direct, in-person training and assistance for the beneficiary. CMS should also institute the condition that the LCMP conducting the evaluation does not have a financial relationship with the seat elevation supplier.

The clinician and supplier work together through the evaluation and assessment process to consider the beneficiary’s medical needs, clinical conditions, and other factors that drive the specific technology recommendation. This may include, but is not limited to, the activities of daily living in the home environment, functional needs and capabilities, and the technology solutions designed to ameliorate the mobility challenges. In addition, as addressed in the ITEM Coalition’s original Reconsideration Request, the team will identify the least costly, but medically appropriate technology and consider contraindications that would prevent the beneficiary from using certain technologies. This approach provides protection for the beneficiary and Medicare’s expenditures as the clinical and technology decision-making process that occurs is documented in the beneficiary’s medical record.

The ITEM Coalition encourages CMS to clarify these issues as recommended in the final NCD and ensure that all beneficiaries for whom seat elevation should be deemed reasonable and necessary are able to access these systems without unnecessary administrative hurdles.

***Support from Congress and Other Stakeholders***

The issue of seat elevation coverage has garnered significant support from lawmakers. In October 2021 and October 2022, CMS received a total of four letters from the House of Representatives and the U.S. Senate, urging the agency to move quickly to advance coverage for these systems as well as power standing systems. Overall, more than 130 bipartisan Members of Congress have called on the agency to cover these important power wheelchair functions.

Additionally, as the agency is aware, the National Council on Disability, a quasi-federal agency that addresses policies impacting people with disabilities, has long supported these efforts. Medicare coverage of seat elevation and standing systems in power wheelchairs remains an important component of the Council’s Health Equity Framework for People with Disabilities, originally released in February 2022. Further, the Council hosted a stakeholder Roundtable discussion on coverage of these systems in August 2022, shortly before CMS opened the initial public comment period beginning the National Coverage Analysis for power seat elevation systems. The Council is preparing to submit a written report on the roundtable, featuring perspectives from all stakeholders in seat elevation and standing system policy, to CMS during the current comment period on the proposed NCD. The Roundtable emphasized the evidentiary foundation for Medicare coverage of these important benefits for persons with mobility impairments with every speaker strongly supporting Medicare coverage of both seat elevation and standing systems.

Finally, we again note that coverage of seat elevation systems has received extensive and unwavering support from the general public and other non-federal stakeholders as well. During the initial public comment period at the opening of the NCA for seat elevation, CMS received over 3,600 separate and unique comments from Medicare beneficiaries with mobility impairments, rehabilitation therapists who address the mobility device needs of beneficiaries, physicians who treat this patient population, rehabilitation hospitals, seating clinics, researchers, manufacturers and suppliers, and the general public. As the agency notes in this proposed decision memo, these comments were unanimous in their support of Medicare coverage for seat elevation systems. At the time of this writing, CMS has received an additional nearly 2,000 comments from stakeholders, including both individuals and organizations supporting the proposed coverage decision and encouraging CMS to include additional populations in the final decision memo.

The ITEM Coalition has also continued to host a public petition through www.Change.org that has garnered over 4,500 signatures to date since being launched on August 14, 2022, the date of the opening of the seat elevation NCA. The petition states as follows:

“The Medicare program currently denies coverage for seat elevation and standing systems in power wheelchairs. This means that Medicare beneficiaries with mobility impairments are forced to go without medically necessary wheelchair technology if they are not able to afford the costs out of pocket. The Medicare program is currently reviewing a request to provide coverage for these critical systems, known as a "National Coverage Determination" or "NCD Request."

If successful, Medicare will recognize for the first time that these systems are "primarily medical in nature," and, therefore, covered durable medical equipment benefits - not convenience or luxury items for wheelchair users. These systems help wheelchair users carry out important daily activities more independently, such as cooking, eating, and toileting. They also provide numerous health benefits, such as decreased risk of falls or injuries when moving in and out of wheelchairs, improved heart and lung functions, increased bone strength, and improved joint mobility, bladder function, and muscle strength.

Medicare has denied access to these technologies for far too long. Sign your name below to request that Medicare provide coverage for seat elevation and standing systems and allow Medicare beneficiaries with mobility disabilities access to the care they need!”

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Once again, we applaud CMS for recognizing the significant clinical evidence and overwhelming public support for covering seat elevation in CRT power wheelchairs and encourage the agency to quickly finalize a coverage decision that ensures all beneficiaries who can benefit from seat elevation are able to access this technology under the Medicare program.

Sincerely,

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I am a reimbursement specialist for Reliable Medical. I have been at this facility for over 11 years now and have been in the medical field for over 40 years. I have serviced many people with seating and wheeled mobility needs. I have seen clients who have been hurt because they were unable to obtain an SE system. And I've seen and heard of people who had to pay professional personnel to assist them in accomplishing things in their home that they could have otherwise done on their own if they had an SE system.

I want to thank CMS for recognizing power seat elevation systems as being primarily medical in nature, meeting the requirements to be deemed DME and reasonable and necessary for Medicare beneficiaries.

I strongly support Medicare coverage for power seat elevation systems to provide access to this enabling technology, for Medicare beneficiaries who qualify for this benefit and as an essential component of a complex rehab PWC.

I request CMS to consider extending seat elevation systems as an accessory to Complex Rehab power wheelchairs, Group 3 and higher.

I completely AGREE that power seat elevation systems are a critical component for many Medicare beneficiaries to transfer to/from their PWC and applaud CMS for recognizing that: transferring from a wheelchair to other surfaces such as a bed, toilet or other surface is a necessary part of the daily routine, transferring is a means to accomplishing MRADLs, and therefore it is considered a medical necessity; and seat-elevating devices improve transfer biomechanics, safety and independence.

I support CMS' proposed criteria that transfers may be accomplished with or without caregiver assistance and/or the use of assistive equipment but request CMS confirm the assistive equipment used for transfers is not limited to the examples provided in the proposed criteria.

I am concerned beneficiaries who perform non-level (uneven) transfers would be precluded from coverage of a seat elevation system if their safest, most effective transfer is performed using a downhill, gravity-assisted method and request CMS remove the words" non-level (uneven)" from the proposed criteria for transfers.

I am also concerned whether the agency intended to prohibit coverage of seat elevation systems for wheelchair users who cannot assist with the transfer themselves and rely significantly on caregiver assistance and/or the use of assistive equipment. Often with a seat elevation system and transfer training the person can rely less on a caregiver and/or assistive equipment to transfer.

Also I am concerned that the reference to weight bearing transfers may exclude certain beneficiaries from accessing a seat elevation system, especially if they cannot transfer themselves and request CMS consider that these beneficiaries still derive medical benefit from a seat elevation system to perform MRADLs in the home once the transfer is complete.

I encourage CMS to consider coverage of a seat elevation system for people who use a patient lift/transfer system to be safely transferred to their PWC and have the capability of using their upper extremities to perform or participate in their MRADLs from a seated position using the seat elevation system.
I encourage CMS to include coverage for Medicare beneficiaries who need a seat elevation system to reach the locations, surfaces and objects in their home required to support their health, safety, and perform or participate in their MRADLs.

I am very concerned that there is no requirement for the seat elevation system to be provided by a supplier that employs a RESNA certified Assistive Technology Professional (ATP) who specializes in wheelchairs and who has direct, in-person involvement with the wheelchair selection for the beneficiary.

I strongly urge CMS to apply the same criteria for coverage of a seat elevation system as are in place for power tilt and/or recline systems and require the seat elevation equipment be provided by a supplier that employs a RESNA certified ATP who specializes in wheelchairs and who is directly involved in the evaluation and recommendation of the seat elevation system.

I also request CMS to follow the requirements of the Power Mobility Device Policy and allow the supplier OR the practitioner to perform the on-site evaluation of the beneficiary's home to verify the beneficiary can adequately maneuver the device considering the physical layout and surfaces, including the vertical environment, for the provision of a seat elevation system.

Thank you for your time and consideration in this matter it is critical to a lot of our clients all over the USA.

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Re: NCA - Seat Elevation Systems as an Accessory to Power wheelchairs (Group 3) (CAG-00461N) - Proposed Decision Memo
March 17, 2023
On behalf of the Clinician Task Force (CTF), we commend the Centers for Medicare and Medicaid Services (CMS) on their proposed the benefit category decision to determine that power seat elevation systems are primarily medical in nature. This is the first step in covering these necessary systems and will surely benefit power wheelchair users in the United States.

However, there are multiple issues with the proposed decision summary:
1. Proposed decision summary evidence: does not address the contribution of power seat elevation systems to contribute to a Group 3 power wheelchair users’ reach and line of sight. The proposed decision summary lacks adequate justification for the narrowly focused evidence question limiting the literature search to transfers. We recognize many potential reasons for this, which are addressed below.
2. The evidence base supports the medical nature of power seat elevation systems for reach and line-of sight, to maintain shoulder, upper spine and neck integrity during MRADL performance and participation in the built environment.
3. Proposed coverage criteria: requires increased clarity of “weight-bearing transfers”. Additionally, an occupational or physical therapist skilled in wheelchair seating and a complex rehab technology supplier (ATP) should be involved in the process to procure a power seat elevation system.
4. The evidence supports that Group 2 power wheelchair users will benefit from power seat elevation systems.

The CTF is a 501c4 non-profit organization comprised of a group of professionals who practice, serve, and provide education to and advocate for individuals who require seating and wheeled mobility products and services. The CTF mission is to provide clinical based expertise to inform and promote public policy, best practices, and positive outcomes regarding people with disabilities who require Complex Rehab Technology (CRT) products and related services. The membership consists of occupational and physical therapists with expertise in seating and wheeled mobility, at least 80% of whom practice in a wide variety of settings including outpatient rehabilitation, private practice, educational settings, community-based programs, or are full-time educators in academic programs. Membership guidelines mandate that no more than 20% of the membership are employed full-time for CRT manufacturer/suppliers. The CTF has been involved in the NCD Reconsideration Request for Power Seat Elevation Systems and Power Standing Systems since the original submission to CMS in September 2020. While we respond to the positive decision on power seat elevation systems, we continue to request forward movement on the request for power standing systems.

The following information describes each of these points further, with support from the evidence.

1. The proposed decision summary does not address the contribution of power seat elevation systems to contribute to a Group 3 power wheelchair users’ reach and line of sight. The proposed decision summary lacks adequate justification for the narrowly focused evidence question limiting the literature search to transfers.

The decision summary for the Decision Memo for Mobility Assistive Equipment CAG-00274N (2005) states, “The development of an assessment in support of Medicare coverage decisions is based on the same general question for almost all requests: “Is the evidence sufficient to conclude that the application of the technology under study will improve final health outcomes for Medicare patients?” (p. 5). Based on this precedence, it isn’t clear why the evidence question in the current proposed decision (CMS, 2023, p. 12) specifically refers to transfers only, as an evidence question consistent with the 2005 memo would guide a search in this manner: “Is the evidence sufficient to conclude that the application power seat elevation systems will improve the final health outcomes for Medicare patients?”. As in the initial ITEM NCD change request, the evidence from a review under this guidance would demonstrate the impact of power seat elevation systems on beneficiary outcomes related to transfers, reach, and line of sight.

The History of Medicare Coverage (CMS, 2023, p. 5) appears to provide an argument for the focused evidence question using the 2006 review of seat elevation as the balance feature on the iBOT was sufficient to justify disregarding a present-day, comprehensive review of power seat elevation systems on Group 3 power wheelchairs. This is a grave oversight for many reasons:

1) The search terms for the iBOT literature review omitted power seat elevation systems. The external technology assessment stated, “Search terms included iBOT 4000, technology assessment mobility equipment, assistive technology, and iBOT 3000” (CMS, 2006, p. 8). The internal technology assessment searched with an intent “…to find research related to the INDEPENDENCE iBOT 4000 Mobility System and how its function provided a medical benefit.” (CMS, 2006, p. 9). These search terms would not have produced literature that provided evidence on the medical nature of power seat elevation systems. Furthermore, the iBOT decision on the Balance Function was in part due to the lack of clinical evidence demonstrating how the Balance Function served a medical purpose (CMS, 2006, p. 14). Without a comprehensive literature review on power seat elevation systems, CMS should not be able to determine if the power seat elevation system is primarily medical in nature for reach and line of sight.

2) The proposed decision summary states, “The NCA concluded the iBOT seat elevation equipment/ balance function was not primarily medical in nature because seat elevation serves the same purpose as other equipment that assist all persons in reaching items out of reach or having an “eye-level” conversation with a standing person.” (CMS, 2023, p. 5) However, the iBOT Balance Function decision was more nuanced than this, and also should not apply to power seat elevation systems.

1. There was insufficient literature to support the medical nature of the Balance Function (iBOT, 2006, p. 14). This statement alone supports the need for a comprehensive evidence review for power seat elevation systems.
2. power wheelchair users, unlike ambulatory persons, are limited to the height of the power wheelchair seat height. Therefore, without power seat elevation, the power wheelchair base itself actually “Prevent(s) the beneficiary from accomplishing the MRADLs entirely” (CMS, 2023, p. 25) and even “Place(s) the beneficiary at reasonably determined heightened risk of morbidity or mortality secondary to the attempts to participate in MRADLs” (CMS, 2023, p. 25) in the following ways:
   1. falls occur when the power wheelchair user reaches outside their base of support
   2. repetitive strain injuries occur due to overhead reaching
   3. risk of malnutrition and dehydration when the power wheelchair user cannot reach food or drink
   4. skin integrity decreases without ability to reach a sink or objects to perform grooming tasks
   5. burns occur when handling hot pots and pans over a stove at a low static seat height
   6. power wheelchair users with children cannot reach their medications, put out of reach of their children for safety

The list is unique as the power wheelchair users who use power seat elevation systems are, but the pattern is the same: power seat elevation systems are primarily medical in nature, the same way that MRADLs are, as defined by CMS in 2005. This is supported in literature by Pettersson et al. (2015) and Chaves et al. (2004).

3) The literature review published in 2006 was 17 years ago and beneficiaries deserve a current literature review prior to excluding access that supports a body function critical to MRADL participation and performance (CMS, 2006).

4) The iBOT and its Balance Function works quite different than power seat elevation systems, as it moves the user to an elevated position by rotating the four wheeled base to balance on two wheels, using the person’s and device’s weight to accomplish this task (CMS, 2006).

CMS proposed the benefit category decision that power seat elevation systems are primarily medical in nature. The National Coverage Determination (NCD) on Mobility Assistive Equipment (MAE) must reflect this change without excluding the use of power seat elevation systems for evidence-based purposes (CMS, 2005b). For this reason, we propose that the NCD on MAE reflect the medical nature of power seat elevation systems, with specific coverage criteria established in the Local Coverage Determination (LCD) on Power Mobility Devices (CMS, 2015). This is consistent with other power seating systems such as tilt and recline.

The coverage criteria should be established from the evidence, which should be approached in a manner that seeks to understand the impact of power seat elevation systems on the health outcomes of Group 3 power wheelchair users.

2. The evidence base supports the medical nature of power seat elevation systems for reach and line-of sight, to maintain shoulder, upper spine and neck integrity during MRADL performance and participation in the built environment.

The proposed decision summary concluded that “Long-term wheelchair users experience the highest level of shoulder pain when transferring to non-level surfaces (Rice et al., 2013). Furthermore, it appears that repetitive transfers are among the causes of shoulder discomfort in those who use power chairs (Jain, Higgins, Katz & Garshick, 2010).” (CMS, 2023, p. 10)

Jain et al. (2010) reported that there were no manual wheelchair users with C5 and C6 complete injuries or higher in their study, and they did not examine transfer type in their study. The power wheelchair users were reported to have “complete tetraplegia”, and clinical experts agree, were likely to transfer dependently or by lift. Therefore, the assumption made in the proposed decision summary, relating repetitive transfers as a source of shoulder pain, cannot rule out that in the power wheelchair users that Jain et al. (2010) studied, the source was likely something different, such as daily activities (or MRADLs, if preferred) performed with a compromised musculoskeletal system.

Previously Presented Evidence on Power Seat Elevation System Impact on Shoulder, Upper Spine, and Neck Integrity
The initial ITEM Reconsideration Request for Mobility Assistive Equipment described a solid evidence base of the medical nature of power seat elevation systems to maintain the shoulder, upper spine and neck integrity of Group 3 power wheelchair users. This information reported that reach is critical to both 1) maintaining shoulder, upper spine, and neck integrity, in a population of people with compromised musculature due to their neurological or congenital condition, and 2) MRADL performance and participation (AOTA OTPF, 2014; Kirby et al., 2002; Mills et al., 2002; Nyland et al., 2000). Furthermore, that power seat elevation is critical to supporting upper spine and neck function and integrity during line-of-sight tasks. Current power seat elevation users use the system often for reach and line-of-sight tasks (GA Institute, 2017; Sonenblum et al., 2019).
An excerpt from the initial reconsideration request states: “When measuring reach to 63.5”, Sabari et al. (2016) found a significant difference in the active range of motion required when subjects were seated in a power wheelchair at 17.5” (at the minimum, static height), and the active range of motion needed when reaching seated in a power wheelchair at 25.5” (positioned at maximum height with power seat elevation). In this task, all participants abducted their shoulder equal to or over 60 degrees to reach the object when seated at the minimum height, with an average shoulder abduction of 85.11 degrees. However, with the power seat elevation feature at maximum height (25.5”), the minimum active abduction utilized was 35 degrees, with an average of 53.39 degrees abduction. Repeated or sustained abduction or flexion over 60 degrees is known to contribute to tendinitis and other musculoskeletal disorders in the shoulder (Bernard/Musculoskeletal disorders, 1997); therefore, power wheelchair users are at great risk of pain and injury due to their need to repetitively reach overhead during MRADLs without the vertical support provided through seat elevation.” Furthermore, MRADL performance and participation in the home support the need for reaching: “The home environment of many wheelchair users’ requires reach above shoulder height to locate, explore, and reach many features, including upper kitchen cabinets (average height 54” at bottom), items in a freezer over refrigerator (50-72” tall), an over-the-stove microwave (50-54” at bottom to 66” at top), and clothes hanging on closet rod (66”) (RESNA position paper, 2019; Sonenblum et al., 2019). Many thermostats, necessary for wheelchair users to control for thermal regulation, are positioned at 60” from the floor, and many light switches are on the wall at 48” (RESNA position paper, 2019).”

Vision is an integral part of MRADL performance and participation, as well as power wheelchair driving (Massengale et al., 2005), and visual demands change when seated in a power wheelchair. For power wheelchair users, the upper visual quadrant, or superior visual field, is relied on more than in the ambulatory population due to the differences in eye height and available trunk positions observed by ambulatory people and people seated in power wheelchair (Kirby et al., 2004). Using seat elevation to provide a level and horizontal gaze has also been shown to decrease hyperextension and compensatory movements when looking up, and to improve interactions with the environment which, in turn, improves safety through obstacle avoidance (Diebo et al, 2016). From the initial request, “With a power wheelchair at minimum seat height, people were shown to utilize an average of 24 degrees cervical extension to look at a computer screen centered at 69.5” from the floor; however, with power seat elevation of 8”, average cervical extension was reduced to 15 degrees, close to a 10 degree reduction (Sabari et al., 2016).”

New Evidence on Power Seat Elevation System Impact on Shoulder, Upper Spine, and Neck Integrity
Additional evidence supports the need to examine power seat elevation systems for shoulder, upper spine, and neck integrity during reaching and line-of-sight tasks. The evidence supports that power seat elevation systems improve the health outcomes of power wheelchair users by maintaining shoulder, upper spine, and neck integrity during tasks that result in common placement of the upper extremity in an awkward position or that exceeds a healthy range and reducing falls with reaching tasks.

MRADL performance and participation is restricted for power wheelchair users stationed at a low static seat height due to the length of the upper extremity and the restriction of the mobility equipment the user acquires when seated in the equipment. This fact is well documented in federal documentation, with oversight from the Americans with Disabilities Act (ADA) accessible reach guidelines and more (ADA, 2014). Although, the ADA does not oversee private house construction, promoting inaccessible housing for wheelchair users. Occupational therapy, the profession that addresses activity of daily living, or MRADL, performance in rehabilitation medicine always considers the task demands, the environment, and the person and their equipment when addressing barriers to occupational performance and participation (AOTA OTPF, 2014). power wheelchair user’s view power seat elevation systems as a function of the power wheelchair itself, not the environment (Vance et al., 2021), and a facilitator for occupational performance. Power seat elevation systems provide the power wheelchair user with the ability to maximize their MRADL performance and participation in their own personal context; it is not feasible that a house can be modified for accessibility at a low static seat height (Masselink et al., 2022; Pettersson et al., 2015). Stoves, for example, require reaching for hot items and are (at best) at countertop level. Some families have children, requiring placement of medications out-of-reach for safety. Consistent with the ADA and these scenarios, Pettersson et al. (2015) found the three largest barriers to independence in the home for power wheelchair users as 1) high, wall-mounted cupboards and shelves in the kitchen, 2) controls in an inaccessible position in the kitchen, and 3) controls in a high or inaccessible position outside of the kitchen and the bathroom. Power seat elevation systems provide access to these areas in the home, enabling MRADL performance and participation.

Power seat elevation systems not only enable independence with MRADLs by providing access to the vertical environment, but also reduce risk of further injury for people who often reach to their periphery when performing MRADLs in the home. The performance and participation of daily activities require upper extremity use, with experts agreeing that 120-130 degrees of flexion and abduction are generally needed in the ambulatory population to perform daily activities, or MRADLs (Vocelle et al., 2022). At a low static seat height, power wheelchair users must utilize greater range of motion for these tasks, and when performing motions at the periphery of maximum range of motion, joint mobility and stability are lowest (NIOSH, 1997; PVA, 2005; Vocelle et al., 2022). Furthermore, body mechanics during activities requiring upper extremity movement and control are important to consider. The National Institute for Occupational Safety and Health Primer on Workplace Evaluation of Musculoskeletal Disorders advises to examine concerns of frequent aches and pains, fatigues, or discomfort that doesn’t go away after an overnight rest (NIOSH, 1997). The document also states, “Manipulative or other tasks requiring repeated or sustained bending or twisting of the wrists…shoulders also impose increased stresses on these joints.” (p. 20), and indicate that awkward postures, poor shoulder or wrist position, wrist deviations, overhead work, and twisting and carrying loads, may place a person at risk of acquiring a musculoskeletal disorder (Figure 1, p. 21-22). While this document addresses an ambulatory, working population of people, underlying medical conditions place wheelchair users at a higher risk of repetitive strain injury with daily activities. Age, sex, connective tissue structure and function, and hormone level are all indicators of shoulder range motion (Vocelle et al., 2022); in adults with neurological and congenital conditions, connective tissue structure and function are already compromised (Barcala et al., 2019; Marigi et al., 2020; Sinnott et al., 2000), and the presence of frequent pain is well documented (CMS; Kovacs et al., 2018; PVA, 2005). This pain requires attention, as pain is an indicator of the potential to develop a medical condition that will require further treatment (NIOSH, 1997). Both repetitive strain injuries and degenerative diseases, such as osteoarthritis, are potential comorbidities for power wheelchair users as the shoulder cartilage and surrounding structure degenerates from frequent use (Barcala et al., 2019; Marigi et al., 2020; Sinnott et al., 2000; Vocelle et al., 2022) with repetitive daily use. As established prior, power seat elevation systems can reduce awkward positions and enable ergonomic upper extremity movement with daily activities by bringing the person closer to the object when reaching, and load when grasping to carry, thus reducing the risk of pain and further injury.

Another risk for power wheelchair users at a static seat height is that to reach high items, they may transition to stand. In literature, a fall resulting from this situation may present as a fall during a transfer, which has been addressed in previous documents (ITEM, 2020; CMS, 2023). However, power wheelchair users often present with limited balance and coordination, and may have poor safety awareness (Peterson & Finlayson, 2007; Petersson et al., 2015), and many are worried about falling enough that it impacts activity participation and quality of life (Abou & Rice, 2022; Sung et al., 2021). Power seat elevation systems provide a safe basis from which to reach items for MRADL performance and participation.

Recognizing this literature as evidence for the medical nature of power seat elevation and establishing coverage criteria to maintain shoulder, neck, and upper spine integrity apart from transfers is extremely important. There are power wheelchair users, such as those with tetraplegia, that likely transfer dependently or by lift, yet still use their upper extremities for daily activities, such as self-feeding and grooming. If the tetraplegia results from a progressive neurological condition, it is possible that the person had a power seat elevation system on their previous chair, but would no longer qualify based on the proposed coverage criteria. This would result in a loss of function for this individual. Additionally, many conditions result in acute tetraplegia (such as high level spinal cord injuries), where the person will be limited in their home environment without the ability to raise their seat height during MRADLs. As the Mobility Assistive Equipment NCD is function based, these restrictions to participation for power wheelchair users must be considered.

Other Funding Sources Cover Power Seat Elevation Systems for Accessing the Vertical Environment
CMS should consider that other funding sources, including Worker’s Compensation, the Department for Veterans Affairs, and AETNA, cover power seat elevation systems for maintaining shoulder, upper spine, and neck integrity during daily activities.

Worker’s Compensation
Worker’s compensation insurances will cover vertical elevation as part of the injured workers’ compensable claim and it is viewed as reasonable and medically necessary for individuals’ function, health, and well-being within their vertical environments at home, work, and communities throughout their remaining lifetime after a catastrophic injury.

Department of Veterans Affairs
Veterans Affairs (VA) Clinical Practice Recommendations for Motorized Wheeled Mobility Devices
(https://www.prosthetics.va.gov/Docs/Motorized_Wheeled_Mobility_Devices.pdf) include general comments for power wheelchairs with enhanced function, specifically stated, “potential advantages to using a power wheelchair with the ability to change vertical position include improved self-esteem, improved social function, enhanced employment potential, enhanced communication, and improved quality of life. Elevation or descent may also result in improved functional independence, allowing the user to access surfaces that cannot be reached from a fixed seated position.” (p. 9, Section D. “Enhanced Power”). In addition, specific written list of indications for the provision of power wheelchairs with an elevating or descending seat include verification that:

Indications

1. Criteria for power mobility have been met.
2. Functional goals have been identified that can be achieved by changes in vertical position.
3. Vocational goals have been identified that can be achieved by changes in vertical position.
4. Communication goals have been identified that can be achieved by changes in vertical position.
5. Patient desires elevation capability and understands/accepts limitations of using a chair with this capability.

The VA also provides guidance with regard to the general contraindications that clinicians should consider before recommending this technology. Those contraindications include:

1. Inadequate cognitive function, judgment, vision, motor coordination or the presence of a sufficiently serious spatial neglect, to preclude with reasonable certainty, safe operation of the device.
2. If there is a history of active seizures in the last six months, clearance should be obtained from a neurologist that the patient’s seizures do not prohibit safe use of a motorized device.
3. A documented history of reckless behavior that threatens physical harm to self and/or others, such as that due to drug-/alcohol impaired functional abilities.
4. Frequent failure of prior prescribed wheeled mobility devices suggesting a pattern of misuse, abuse or neglect.
5. Home/community environment will not support use of motorized device.
6. Fails training with device(s). Every effort should be made to resolve deficiencies and should include consideration of retraining and equipment alterations and modifications.

AETNA
From the Aetna Wheelchair and Power Operated Vehicle Clinical Policy Bulletin dated 4/28/2022 http://www.aetna.com/cpb/medical/data/200_299/0271.html states: Power Seat Elevators may be covered by Aetna if:

1. all criteria for power wheelchair are met;
2. PT/OT Specialty Evaluation completed by LCMP with no financial relationship with supplier;
3. Provided by RESNA-certified ATP who specializes in wheelchairs and who has direct in-person involvement in the wheelchair selection;
4. Clinical documentation must support that member does not have ability to transfer independently from a static seat height but by adjusting the seat height the member is able to:
   1. Stand and transfer to and from the wheelchair; or
   2. transfer across unequal seat heights; or
   3. pivot for lateral transfer; or
5. The member is at high risk for repetitive strain injury or has limited range of reach of the upper extremities, which prohibits participation in MRADLs from a static seat height due to:
   1. limited upper extremity strength; or
   2. limited upper extremity active range of motion; or
   3. deformity; or
   4. short stature.

3.The proposed coverage criteria, apart from its limited scope, requires increased clarity of “weight-bearing transfers”. Additionally, an occupational or physical therapist skilled in wheelchair seating and a complex rehab technology supplier (ATP) should be involved in the process to procure a power seat elevation system.

The proposed NCD changes addressing coverage criteria is limited in scope and unclear. “Weight-bearing transfers” does not determine if the weight must be born by the client or assistant and as described, does not exclude dependent transfers, although it appears this was CMS’ intent. If modifying this proposed coverage criteria, establishing the base level of effort that the person must provide, perhaps through level of physical assist (eg. “Individual must provide a minimum of maximum assist with or without caregiver or assistive equipment equipment”) would utilize clearer language for health care providers and beneficiaries; although, would exclude a population of people who need power seat elevation for MRADL performance yet cannot assist with transfers.

Furthermore, the complex rehab technology supplier (ATP) must be involved with these equipment decisions. The health care provider and ATP work together with the beneficiary to make these necessary decisions on equipment, combining knowledge of the health care condition and function with equipment expertise to promote positive health outcomes for the individual (CTF, 2021; Eggers et al., 2009).

For consistency with the evidence base and the current power seating functions of tilt and recline, we continue to recommend that the NCD establish the benefit category decision that power seat elevation systems are primarily medical in nature and the LCD specify coverage criteria, such as that previously recommended:

POWER SEAT ELEVATION SYSTEM:

A power seat elevation system will be covered if criterion 1, 2, and 3 are met and if criterion 4, 5 or 6 is met:?

1. The beneficiary meets the coverage criteria for a Group 3 power wheelchair described in the Power Mobility Devices (“PMD”) LCD; and
2. A specialty evaluation that was performed by a licensed/certified medical professional, such as a physical therapist (“PT”), occupational therapist (“OT”), or physician who has specific training and experience in rehabilitation wheelchair evaluations of the beneficiary’s seating and positioning needs. The PT, OT, or physician may have no financial relationship with the supplier; and
3. The wheelchair is provided by a supplier that employs a RESNA-certified Assistive Technology Professional (“ATP”) who specializes in wheelchairs and who has direct, in-person involvement in the wheelchair selection for the beneficiary.
4. The beneficiary does not have the ability to transfer independently from a static seat height, but by adjusting the seat height the beneficiary is able to:
   • stand and transfer; or
   • transfer across otherwise unequal seat heights; or
5. The beneficiary is at high risk for repetitive strain injury or has limited range of reach of the upper extremities, which prohibits performance of or participation in MRADLs from a static seat height due to limited upper extremity strength, limited upper extremity active range of motion, deformity, or short stature; or
6. The beneficiary has limitations in vision, in neck range of motion and/or posture induced neck reflex activity that prohibits performance of or participation in MRADLs from a static seat height.

This coverage criteria may be modified to include Group 2 power wheelchair users as well, as a specialty evaluation with a physical or occupational therapist and a complex rehab technology supplier (ATP) is indicated when recommending power options to ensure appropriateness and usability for the individual beneficiary.

4. Group 2 power wheelchair users would benefit from power seat elevation systems for transfers.

The proposed decision summary described a comprehensive literature review with important evidence resulting in a preliminary consideration to support power seat elevation systems for Group 2 power wheelchair users. We agree with the evidence base that Group 2 power wheelchair users who sit-to-stand transfer, such as those with cardiovascular and pulmonary conditions, are likely to experience reduced lower leg function and activity tolerance needed for the transfer (Karmarker et al., 2011).

Beneficiaries needing a power wheelchair with an amputation have unique needs. This population of people may perform a sit-to-stand or lateral transfer depending on the amputation site, prosthetic, and capabilities. Vascular disease accounts for a large amount of older adult amputations, and age, comorbidities, premorbid function, the level of amputation, remaining limb and psychosocial factors all contribute to the person’s potential for recovery (Fleury et al., 2013). After an amputation, the sit-to-stand motion requires 120% greater oxygen consumption even with a prothesis (Fleury et al., 2013). Furthermore, a quadrilateral amputee may benefit from a power seat elevation system for transfers (Lange, 2019). Power seat elevation system usage during transfers and reaching tasks may alleviate pain and subsequent injury, such as for people with bilateral lower leg amputations acquired as a child or an adult, and therefore sit-to-stand and lateral transfers must be included when establishing coverage criteria for this population of people. Reach may be an important consideration as well, for a beneficiary with one lower extremity amputation may stand to reach an item without a power seat elevation system, yet at risk for fall due to reaching from an unstable surface.

Consistent with the LCD on Power Mobility Devices (L337898) for tilt and recline power seating systems, an evaluation for a Group 2 power wheelchair with power seat elevation should be performed by a physical or occupational therapist and a complex rehab technology supplier (ATP).

References

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To Whom It May Concern,

I fully support CMS funding power seat elevation technology on powered mobility wheelchairs, for both Group 2 and Group 3 power bases, as this technology enables certain individuals to perform the following medically-necessary functions:

* Facilitate reach biomechanics, safety and range
* Improve transfer biomechanics, safety and independence
* Enhance visual orientation and line-of-sight
* Support physiological health, safety and well-being.
* Decrease hyperlordotic position of the neck
* Promote stable seated positioning
* Reduce symmetric tonic neck reflex (STNR) activity
* Improve safety with performance/participation in ADLs.
* Promote communication, social engagement, self-esteem and integration.
* Improve wheelchair pedestrian safety.

For these reasons, I encourage CMS to approve funding for power seat elevation technology for those beneficiaries who qualify.

Thank you for your consideration,

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March 17, 2023
Ms. Chiquita Brooks-LaSure
Administrator
Centers for Medicare and Medicaid Services
U.S. Department of Health and Human Services
200 Independence Avenue SW
Washington, DC 20201

RE: Seat Elevation Systems as an Accessory to Power Wheelchairs (Group 3)

Dear Administrator Brooks-LaSure:

VNS Health appreciates the opportunity to comment on CMS’s proposal that Medicare cover seat elevation systems as an accessory to power wheelchairs.

As one of the oldest and largest home-and community-based safety net health care organizations in the U.S., VNS Health has long-standing experience serving people with disabilities as both a provider of health care services in the home and through managed care plans that primarily serve Medicaid enrollees or dually eligible beneficiaries. Our comments draw heavily on our own experiences serving vulnerable and underserved New Yorkers with highly complex needs and disabilities.

Seat elevation in power wheelchairs can directly impact an individual’s flexibility and independence. Our plan members who use power wheelchairs report how difficult it is to reach items, perform tasks like laundry and washing dishes, transfer to and from their beds and commodes, and many other activities that they could otherwise independently perform if they had the supports in place. Moreover, beneficiaries who cannot easily transfer due to height barriers risk being confined in the seat for long stretches of time without adequate movement; this in turn, has caused beneficiaries to experience worse health outcomes in the forms of urinary infections and wounds.

With the provision of a seat elevation, more of our members who use power wheelchairs will have the opportunity to perform these activities with ease and without fear of sustaining injuries from straining or from falling when attempting to transfer at uneven heights. For instance, seat elevations in wheelchairs offer beneficiaries the ability to independently transfer to a bed or commode with greater ease. As such, seat elevation can reduce reliance on personal care attendants to perform these tasks.

Besides the physical benefits that this coverage offers, there is a broad spectrum of potential benefits that this coverage would bring to our beneficiaries with the most complex care. For example, adjusting the wheelchair and being more mobile in the home and community can have a significant psychological impact and promote overall well-being. Our beneficiaries often share their daily life experiences with their care managers, and we have heard how seat elevation gives them a sense of dignity; the added height allows beneficiaries to speak face-to-face with others and to keep conversations at eye level without being perceived as spoken down to.

While we applaud CMS’s proposal to cover seat elevation as a DME covered benefit, we urge reconsideration that the benefit be limited to wheelchair users who can perform weight bearing transfers. Many wheelchair users cannot perform weight bearing transfers but would still benefit greatly from the seat elevation since this technology helps individuals to reach items and promotes the independence and sense of dignity noted earlier. We recommend that the criteria for meeting the ‘reasonable and necessary’ standards be extended to anyone who is clinically evaluated as benefiting from this equipment.

We also request that a cost impact analysis be performed on the utilization of this new benefit, as it has the potential to increase DME costs substantially, especially for dual special needs plans (DSNPs) like VNS Health’s, which have a higher proportion of power wheelchair users.

Thank you for the opportunity to comment and for your time and attention to this important benefit. Should you have any questions regarding the above comments, please do not hesitate to reach out to Dan Lowenstein, Senior Vice President of Government Affairs, at dan.lowenstein@vnshealth.org.

Sincerely,

Dan Savitt
President & CEO
VNS Health

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Having spent five years working in health care, and as a graduate student in the field of occupational therapy, I have met many people who use wheelchairs, whether they be manual or power electric. Unless they are lying in bed or relaxing in their recliner, these individuals spend much of their waking hours seated in their wheelchair. Without being able to stand unsupported, it is difficult for them to fully participate within their community or even within their own home. Having witnessed each individual use these devices to move within and interact with their environment, I believe that wheelchair elevation and standing systems could be very beneficial to their physical, functional, and psychosocial wellbeing. Because of this, I fully support its coverage by Medicare for group 3 power wheelchairs.

If you work in an office or sit at a desk for much of your work day, you may notice some changes after a certain amount of time has elapsed. Your back and neck may begin to hurt, you may feel tired or restless, and the bony parts of your body that are in contact with the chair may become sore. If you were to remain in this position for days, then any of these issues could eventually evolve into more serious health problems. However, by the end of the work day, you can mitigate these issues by standing up and stretching your legs. Wheelchair users can benefit from standing in similar ways. In fact, standing can provide many advantages that most people may not immediately consider. These include, but are not limited to: increased bowel and bladder function; decreased urinary tract infections; reduced risk of bed sores; decreased spasticity; and preservation of bone mineral density (Dunn et al., 1998; Arva et al., 2009).

In addition to these medical benefits, both wheelchair elevation and power standing can increase the user's functional capabilities. Users are able to more easily reach for and access items at standing level, which in turn can increase their independence and their involvement in various daily activities (Arva et al., 2009). Additionally, these wheelchair functions reduce the need to consistently look upwards and can have clear psychosocial benefits, allowing for easier communication with family, friends, and peers at eye level.

Given the many benefits that wheelchair elevation and power standing can provide, I strongly recommend that CMS cover these features. Doing so would make this technology more widely available to those who need it, and drastically improve the lives of many Americans. Thank you for your consideration and allowing us the opportunity to share our thoughts on the matter.

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It is vital that power seat elevation systems be provided when medically necessary for Medicare recipients! I appreciate the fact that CMS is considering additional options for providing this feature when it will improve a patient's function!

Some individuals are capable of transferring independently if the wheelchair seat is at an appropriate height to assist them in standing up or to place them at the same level as the surface to which they are transferring. Others are able to transfer with assistance more effectively with the seat height adjusted. The elevated seat option is also vital for transfers done by caregivers. One man who is dependent for transfers had a caregiver transfer him using a lift. When the lift broke, and replacement was delayed, the caregiver had to lift the man in and out of his high bed for months. The caregiver developed serious and prolonged back pain. A wheelchair at the height of the bed would have facilitated the transfer and protected the caregiver's back.

Someone else had an older chair with power seat elevation, which she used to reach for items on a counter and to get a drink out of the refrigerator independently. This enabled her to have independence and to get what she needed when she wanted it. Because of generalized stiffness, she was unable to bend her body forward or to straighten and raise her arm to reach. When a replacement wheelchair was required, the seat elevation was denied. The woman had to hope that the old wheelchair would not fail while she appealed the denial. As a result of her clarity in explaining why she needed the seat elevation and my additional explanations to the administrative law judge, the seat elevation was approved.

A man needs the power seat elevation for safety. When he looks up from his wheelchair at an adult who is communicating with him, and when he looks up to initiate communication, he tends to choke on his saliva and aspirate. This man has been hospitalized multiple times for pneumonia. During a trial with a power wheelchair with the seat elevated 10", he was able to communicate with people who were standing without tipping his head back. The power wheelchair with tilt, recline, and seat elevation was ordered, and the seat elevation component was denied! The man had not been considered a candidate for independent power mobility for more than 10 years after his earlier power chair stopped functioning, and the order for the new chair was not approved. Because of the pandemic, the wheelchair dealer did nothing with the order and did not share documents which would have allowed an appeal. Currently specifications for a new order of the wheelchair are being developed.

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As per the fourth edition of the Occupational Therapy Practice Framework: Domain and Process, the literature with which occupational therapists use to structure how they approach their profession, standing is considered critical in occupations (AOTA, 2020). Occupations, or activities individuals need to do or want to do, are meaningful to the client and promote the individual’s health and wellness. For many individuals, their assistive technology stands in between their ability to participate in their occupations and to maintain their daily independence. In the case of power standers, clients are given the opportunity to more fully integrate into their daily occupations in ways that may be overlooked. Power standers enable the user to “stand” eye level with colleagues, loved ones, strangers, and associates, such that social participation is done equitably. This includes allowing users to engage in intimacy with partners in a natural and comfortable manner. Additionally, the accessibility of an assistive device user to stand has been clinically supported to improve performance and satisfaction in user ability to engage in toileting and toilet hygiene by relieving symptoms of constipation, home establishment and management such as cleaning, and meal preparation and cleanup such as reaching objects in high shelves (Gohlke & Kenyon, 2022, p. 6). Another interesting point brought up by literature was that standing with the aid of an assistive device is shown to improve lower extremity passive range of motion after only six months of usage (Gohlke & Kenyon, 2022, p. 9). Please sincerely consider coverage for seat elevation systems and standing devices, as the ability to stand is crucial towards independence and the quality of life for individuals reliant on assistive devices.

References

American Occupational Therapy Association. (2020). Occupational therapy practice framework: Domain and process. American Journal of Occupational Therapy, 74(2), 7412410010p1-7412410010p87. https://doi.org/10.5014/ajot.2020.74S2001 Gohlke, J. H., & Kenyon, L. K. (2022). Exploring powered wheelchair standing device use in children and adults: a longitudinal case series. Disability and Rehabilitation: Assistive Technology, 1-13. https://doi.org/10.1080/17483107.2022.2120101

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As a graduate student currently studying occupational therapy, I believe there ar many bejefits of seat elevation systems for power wheelchairs that can overall have a great impact on one's performance in various occupations, or activities that one wants to do or needs to do in their lives. One occupation is social participation, and a key factor in social participation is eye contact with those you are communicating with. Seat elevation systems for power wheelchairs can allow many people to be at eye level with their peers and look them straight in the eyes, which is something so important and often taken for granted. According to an article published in Paraplegia News, one veteran explained that he felt thar he received more respect when he was able to stand through the use of a stand-up wheelchair. He reported that his self-confidence and morale when speaking with others at eye level increased as well (Abelar, 2022).

Along with improving the occupation of social participation, seat elevation systems can increase one's independence in activities of daily living, or ADLs, and instrumental activities of daily living, or IADLs. ADLs include grooming and self care, health management, eating, bathing, and toileting. IADLs include activities like preparing meals, doing laundry, grocery shopping, and managing chores around the house. Having the ability to stand through the use of a power wheelchair reduces the reliance on others for assistance. In a qualitative study that looked at the experiences of adolescents with Duchenne muscular dystrophy using standing wheelchairs, the adolescents described being able to stand to brush their teeth and do their hair, reach for library books, and stand when purchasing items in shops. They explained the happiness and decreased frustration they felt since they were able to do things they wanted to do when they wanted to do them (Vorster et al., 2019).

Overall, seat elevation systems provide those who are unable to stand to be able to do activities with a greater sense of control and confidence. It lessens limitations that may cause distress, and it can empower many to complete their daily occupations comfortably. Thank you for the opportunity to submit this comment and I encourage Medicare to approve the coverage of seat elevation and standing systems so that wheelchair users can access the care they need and participate in their desired occupations.

Rebekah Melendez, OTS

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As an occupational therapy student, the importance of advocating for client is central to the profession. Wheelchairs are an example of an incredibly important avenue through which advocacy can be provided so that the overall quality of life of many people can be positively impacted. As each client’s health condition and needs may vary, it is important that wheelchairs are adaptable to suit the specific necessities of those in need of them. Thus, the provision of Medicare coverage for seat elevation within power wheelchairs is incredible to hear. This can better serve many people with various diagnoses who are limited in their ability to stand independently. In regards to occupational therapy, standing can allow users to better participate in several occupations such as shopping, leisure activities such as sports or games, and social participation with others. In these occupations, standing will allow users to better reach objects or counters. Along with this, standing can help individuals converse with others at a more comfortable level at school, parks, or any other setting. Findings from a 2019 study conducted among adolescents diagnosed with Duchenne’s muscular dystrophy highlighted that the use of a powered standing wheelchair allowed individuals to have a better sense of self confidence and independence. For instance, it allowed participants to reach for library books on their own and also helped an individual in handling pain (Vorster et al., 2019). Thus, standing is heavily important to occupation because for someone who may have been unable to do such tasks on their own beforehand, this is a huge life change. Standing can help people connect with one another, and can help decrease stigma an individual with a health condition may feel.

Sincerely,

References

Vorster, N., Evans, K., Murphy, N., Kava, M., Cairns, A., Clarke, D., Ryan, M. M., Siafarikas, A., Rowe, P. W., Parkinson, S., Gaynor, O., Chiu, L., Anderson, J., Bayley, K., Jacoby, P., Cross, D., & Downs, J. (2019). Powered standing wheelchairs promote independence, health and community involvement in adolescents with Duchenne muscular dystrophy. Neuromuscular disorders : NMD, 29(3), 221–230. https://doi.org/10.1016/j.nmd.2019.01.010

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I am writing to express my strong support for the inclusion of seat elevation systems as a standard accessory on power wheelchairs. As a user of a manual wheelchair, I understand the limitations and challenges that come with being confined to a seated position for long periods of time.

I believe that the inclusion of seat elevation systems on power wheelchairs would significantly benefit wheelchair users. The ability to adjust the seating position offers many advantages, including improved circulation, pressure relief, and the ability to reach higher surfaces. Additionally, it promotes better social interaction and engagement, as the user can be at eye-level with others in a standing position.

Although seat elevation systems are often not included as a standard accessory on power wheelchairs, I strongly believe that they should be. This would provide wheelchair users with greater independence and mobility, and would allow them to experience the numerous benefits that come with seat elevation systems.

I urge you to prioritize the needs of wheelchair users and to consider the importance of including seat elevation systems as a standard accessory on all power wheelchair models. Thank you for your consideration of this important matter.

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I am writing to express my strong support for the inclusion of seat elevation systems as a standard accessory on power wheelchairs. As a user of a manual wheelchair, I understand the limitations and challenges that come with being confined to a seated position for long periods of time.

I believe that the inclusion of seat elevation systems on power wheelchairs would significantly benefit wheelchair users. The ability to adjust the seating position offers many advantages, including improved circulation, pressure relief, and the ability to reach higher surfaces. Additionally, it promotes better social interaction and engagement, as the user can be at eye-level with others in a standing position.

Although seat elevation systems are often not included as a standard accessory on power wheelchairs, I strongly believe that they should be. This would provide wheelchair users with greater independence and mobility, and would allow them to experience the numerous benefits that come with seat elevation systems.

I urge you to prioritize the needs of wheelchair users and to consider the importance of including seat elevation systems as a standard accessory on all power wheelchair models. Thank you for your consideration of this important matter.

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Occupational Therapy Student
The ability to have the seat elevation system in power wheelchairs is incredibly important for people of all ages. The use of power wheelchairs gives people the intrinsic desire to be mobile and explore the environment around them (Casey, et.al., 2013). This function could improve a child’s ability to participate in occupations such as playing with other children, education, or leisure activities. For example, being able to stand in a circle and gossip/talk with peers. Having that face-to-face interaction is critical for children to develop social participation.
Additionally, it would be beneficial for older adults to improve their participation in their occupations of work, social participation, health management, and household chores. For example, if their job was stocking shelves in a grocery store. The individual would still be able to participate fully in their occupation of work. The standing function of the power wheelchair would give people with a disability a chance to look people in the eye and connect meaningfully, such as being on the same wavelength as others (Gohlke & Kenyon, 2022). By using this function, individuals would also improve their sense of independence and freedom (Casey, et.al., 2013, Gohlke & Kenyon, 2022). They would not have to rely on or depend on someone to get something out of a high cabinet or completely rearrange their house to have everything lower. The individual’s self-esteem would also improve since sitting in a chair can make a person feel small and that everyone looks down on them (Gohlke & Kenyon, 2022).
In addition, the seat elevation function is beneficial for people’s occupations and our natural body functions, such as helping to facilitate the digestion of food and more. It would decrease pressure sores and allow the individual to switch position into a more natural stance. Our bodies aren’t meant to be sitting down all day, every day. It can also help with the passive range of motion of the individual’s lower limbs, decrease pain and improve their quality of life (Gohlke & Kenyon, 2022). This function would be helpful to improve and prevent various other co-morbidities that the person could develop. For example, developing contractures in their lower limbs, which could lead to more difficulties while performing their occupations. Overall, this function needs to be available to everyone through Medicare because it would positively impact the individual’s participation in various occupations, their normal body functions, and their overall quality of life.
By: Courtney Anderson, OTS

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Dear CMS,

I would first like to thank you for the benefit category decision and recognizing power seat elevation as primarily medical in nature as well as the opportunity to comment. I am an OT Student with Level 2 FW experience in adult populations who require Power mobility devices for mobility. I fully support coverage for seat elevation because I see the functional impact it has on the ability to remain independent, on performing ADLs as well as reaching, grasping items to engage in daily tasks. I have seen clients who could not perform daily tasks without seat elevation, from accessing kitchen and bathroom cabinets, to accessing sinks in restaurants for hand hygiene, to reaching clothes in their closet, to safely cooking on the stove top and using kitchen appliances to prepare their own meals. I believe Medicare should finalize its proposal to cover seat elevation systems in PWCs for Medicare beneficiaries with mobility disabilities.

I have 4 main concerns with the proposed decision summary which include:

1. The proposed decision summary does not address the contribution of power seat elevation systems to contribute to a Group 3 power wheelchair users’ reach and line of sight. The proposed decision summary lacks adequate justification for the narrowly focused evidence question limiting the literature search to transfers.
   ? I would like to strongly encourage a more comprehensive evidence search, and broaden the evidence question consistent with previous national coverage analyses (NCA).
   ? The proposed decision for the benefit category decision established the medical nature of power seat elevation, so a broader question examining the full impact of these systems is warranted.
2. For Group 3 power wheelchair users, the evidence base supports the medical nature of power seat elevation systems for reach and neck positioning in the built environment.
   1. The evidence in the proposed summary communicates that power wheelchair users shoulder pain is solely due to transfers; however, the breadth of research related to shoulder biomechanics with shoulder function was disregarded.
   2. The evidence presented in the initial ITEM submission supported the inclusion of reach and line of sight for shoulder, neck and upper spine function.
   3. Notable studies supporting power seat elevation systems for shoulder function:
      1. Sonenblum SE, Maurer CL, Hanes CD, Piriano J, Sprigle SH. Everyday use of power adjustable seat height (PASH) systems. Assist Technol. 2019. doi: 10.1080/10400435.2019.1634659
      2. Sprigle S. Survey of users of wheelchair seat elevators. Georgia Institute of Technology. 2017. https://smartech.gatech.edu/bitstream/handle/1853/59106/seat_elevator_survey_report.pdf?sequence=1&isAllowed=y. Accessed March 20, 2020.
         1. 75-95% of PWC users reported using their power seat elevation feature for reaching ‘often’ or ‘sometimes’.
      3. Sabari J, Shea M, Chen L, Laurenceau A, Leung E. Impact of wheelchair seat height on neck and shoulder range of motion during functional task performance. Assist Technol. 2016;28(3):184-189. doi: 10.1080/10400435.2016.1140692.
         1. When measuring reach to 63.5”, Sabari et al. (2016) found a significant difference in the active range of motion required when subjects were seated in a PWC at 17.5” (at the minimum, static height), and the active range of motion needed when reaching seated in a PWC at 25.5” (positioned at maximum height with power seat elevation). In this task, all participants abducted their shoulder equal to or over 60 degrees to reach the object when seated at the minimum height, with an average shoulder abduction of 85.11 degrees. However, with the power seat elevation feature at maximum height (25.5”), the minimum active abduction utilized was 35 degrees, with an average of 53.39 degrees abduction.
      4. Bernard BP. Musculoskeletal disorders and workplace factors (97B141). Cincinatti, OH: US Department of Health and Human Services, National Institute for Occupational Safety and Health; July, 1997.
         1. Repeated or sustained abduction or flexion over 60 degrees is known to contribute to tendinitis and other musculoskeletal disorders in the shoulder.
   4. Notable studies supporting power seat elevation systems for neck and upper spine function:
      1. Sabari J, Shea M, Chen L, Laurenceau A, Leung E. Impact of wheelchair seat height on neck and shoulder range of motion during functional task performance. Assist Technol. 2016;28(3):184-189. doi: 10.1080/10400435.2016.1140692.
         1. With a PWC at minimum seat height, people were shown to utilize an average of 24 degrees cervical extension to look at a computer screen centered at 69.5” from the floor; however, with power seat elevation of 8”, average cervical extension was reduced to 15 degrees, close to a 10-degree reduction.
      2. Kirby RL, Fahie CL, Smith C, Chester EL, Macloed DA. Neck discomfort of wheelchair users: effect of neck position. Disabil Rehab. 2004;26(1):9-15. doi: 10.1080/09638280310001621451.
         1. Wheelchair users extended their cervical spine 11 degrees to look at a seated person, and 27 degrees to look at a standing person.
         2. Repetitive cervical extension, which occurs when looking up frequently, during physical environment navigation and MRADL performance may lead to pain and injury. PWC users have reported approximately 15% greater neck pain than the general population.
      3. Diebo B, Challier V, Henry J, et al. Predicting cervical alignment required to maintain horizontal gaze based on global spinal alignment. Spine. 2016;41(23):1795-1800.
         1. Using seat elevation to provide a level and horizontal gaze has also been shown to improve interactions with the environment which, in turn, improves safety through obstacle avoidance.
         2. People with thoracic kyphosis must hyperextend into cervical lordosis to maintain line of sight.
   5. Additional (new) evidence supports the medical nature of power seat elevation systems in supporting reach and line of sight to maintain shoulder, neck and upper spine integrity.
      1. OSHA Department of Labor (https://www.osha.gov/ergonomics) –
      2. NIOSH document (March, 1997) (https://www.cdc.gov/niosh/docs/97-117/)
         1. 7 step pathway for evaluating musculoskeletal concerns: 1) reports of frequents aches/pains, or job tasks that require repetitive, forceful exertions
         2. Musculoskeletal disorders reflect a more gradual or chronic development, not typically the result of an acute event, and with distinct features, often defined primarily by the location of the pain
         3. “ergonomics”: “the science of fitting workplace conditions and job demands to the capabilities of the working population” (p. 2).
         4. “Excessive reach”: Based on body measurement data indicating comfortable or normal seating and standing arm reach distances for the majority of the male and female population. (Table 4, p. 29).
         5. “lifting loads”: takes account of the horizontal distance of load from the body, vertical locations of hands at the beginning and end of lift, vertical distance of the load moved, frequency rat of lifting, balance (Table 4, p. 29)
         6. Table 1 (p. 5) – investigated work settings from NIOSH investigations showing evidence of WMSDs includes stationary tasks such as sewing, decorating or etching glass, sustained data entry to upper extremity tasks done with functional mobility (eg. Described by cleaning, lifting, carrying; in tasks such as cleaning metal tanks, driving over rough terrain, grinding, assembly work) – all require reach.
         7. ADA Standards for Accessible Design Title III Regulation 28 CFR Part 36 (1991) (https://www.ada.gov/law-and-regs/design-standards/1991-design-standards/).
            a. This document sets guidelines for accessibility to places of public accommodation and commercial facilities by individuals with disabilities as well as details measurements for accessible forward and side reach from wheelchair level.
   6. Power seat elevation systems support participation in and performance of MRADLs.
      1. Daily activities that require power seat elevation systems: progressive lens wearers, safe meal preparation, cleaning, manipulating a chain lock on apartment doors for security, latching/unlatching door locks for added safety, and keeping medications out of reach of children.
      2. Many of my clients could not live alone and would be in a facility without power seat elevate to perform and direct their care.
   7. Other funding sources that cover Power Seat Elevation Systems:
      1. AETNA: More information can be found in updated?Aetna Wheelchair and Power Operated Vehicle Clinical Policy Bulletin dated 4/28/2022?http://www.aetna.com/cpb/medical/data/200_299/0271.html. Power Seat Elevators may be covered by?Aetna?if:
         1. all criteria for PWC are met;
         2. PT/OT Specialty Evaluation completed by LCMP with no financial relationship with supplier;
         3. Provided by RESNA-certified ATP who specializes in wheelchairs and who has direct in-person involvement in the wheelchair selection;
         4. Clinical documentation must support that member does not have ability to transfer independently from a static seat height but by adjusting the seat height the member is able to:
         ? Stand and transfer to and from the wheelchair; or
         ? transfer across unequal seat heights; or
         ? pivot for lateral transfer; or
         d. The member is at high risk for repetitive strain injury or has limited range of reach of the upper extremities, which prohibits participation in MRADLs from a static seat height due to
         ? limited upper extremity strength, or
         ? limited upper extremity range of motion; or
         ? deformity; or
         ? short stature.
         ? Worker’s compensation insurances will cover vertical elevation as part of the injured workers’ compensable claim, and it is viewed as reasonable and medically necessary for individuals’ function, health, and well-being within their vertical environments at home, work, and communities throughout their remaining lifetime after a catastrophic injury.
         ? Veterans Affairs (VA) Clinical Practice Recommendations for Motorized Wheeled Mobility Devices (attached) include general comments for power wheelchairs with enhanced function, specifically stated?(pg. 9 Section D. Enhanced Power) ‘potential advantages to using a power wheelchair with the ability to change vertical position include improved self-esteem, improved social function, enhanced employment potential, enhanced communication, and improved quality of life. Elevation or descent may also result in improved functional independence, allowing the user to access surfaces that cannot be reached from a fixed seated position.’ In addition, specific?written list of indications for the provision of power wheelchairs with an elevating or descending seat include verification that:
      2. iv. Indications:
         1. Criteria for power mobility have been met.
         2. Functional goals have been identified that can be achieved by changes in vertical position.
         3. Vocational goals have been identified that can be achieved by changes in vertical position.
         4. Communication goals have been identified that can be achieved by changes in vertical position.
         5. Patient desires elevation capability and understands/accepts limitations of using a chair with this capability.
            ? General Contraindications:
            ? Inadequate cognitive function, judgment, vision, motor coordination or the presence of a sufficiently serious spatial neglect, to preclude with reasonable certainty, safe operation of the device.
            ? If there is a history of active seizures in the last six months, clearance should be obtained from a neurologist that the patient’s seizures do not prohibit safe use of a motorized device.
            ? A documented history of reckless behavior that threatens physical harm to self and/or others, such as that due to drug-/alcohol impaired functional abilities.
            ? Frequent failure of prior prescribed wheeled mobility devices suggesting a pattern of misuse, abuse or neglect.
            ? Home/community environment will not support use of motorized device.
            ? Fails training with device(s). Every effort should be made to resolve deficiencies and should include consideration of retraining and equipment alterations and modifications.
3. The proposed coverage criteria requires increased clarity of “weight-bearing transfers” and should include transfers other than weightbearing if the person cannot be transferred without seat elevate. Additionally, an occupational or physical therapist skilled in wheelchair seating and a complex rehab technology supplier (ATP) should be involved in the process to procure a power seat elevation system.
   1. OT/PT and ATP are currently required for Group 3 PWCs and should continue to be required for seat elevate. Both bring different skills to the table as far as understanding both physical needs as well as equipment options.
   2. The beneficiary needs to qualify for a Group 2 or Group 3 PWC base prior to the power seat elevation system.
   3. There needs to be a much clearer and stronger explanation of “weight-bearing transfers” so that beneficiaries can either qualify or not.
   4. Background: ITEM proposed coverage criteria for power seat elevation systems, based on the evidence, as follows: POWER SEAT ELEVATION SYSTEM: A power seat elevation system will be covered if criterion 1, 2, and 3 are met and if criterion 4, 5 or 6 is met:??
      1. The beneficiary meets the coverage criteria for a Group 3 PWC described in the Power Mobility Devices (“PMD”) LCD; and
      2. A specialty evaluation that was performed by a licensed/certified medical professional, such as a physical therapist (“PT”), occupational therapist (“OT”), or physician who has specific training and experience in rehabilitation wheelchair evaluations of the beneficiary’s seating and positioning needs. The PT, OT, or physician may have no financial relationship with the supplier; and
      3. The wheelchair is provided by a supplier that employs a RESNA-certified Assistive Technology Professional (“ATP”) who specializes in wheelchairs and who has direct, in-person involvement in the wheelchair selection for the beneficiary.
      4. The beneficiary does not have the ability to transfer independently from a static seat height, but by adjusting the seat height the beneficiary is able to:
         1. stand and transfer; or
         2. transfer across otherwise unequal seat heights; or
      5. The beneficiary is at high risk for repetitive strain injury or has limited range of reach of the upper extremities, which prohibits performance of or participation in MRADLs from a static seat height due to limited upper extremity strength, limited upper extremity active range of motion, deformity, or short stature; or
      6. The beneficiary has limitations in vision, in neck range of motion and/or posture induced neck reflex activity that prohibits performance of or participation in MRADLs from a static seat height.
   5. Consider covering all types of transfers, not just weightbearing. There are many of my clients who use transfer boards with amputations (non-weightbearing), can only be lifted by caregivers if at a higher height, and can only be transferred in a press over style transfer if going downhill with the seat higher. 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.
4. Group 2 power wheelchair users would benefit from power seat elevation systems for transfers. However, the requirements of these systems, due to the beneficiary needs and wheelchair base components, are different than those of power wheelchair systems on Group 3 power wheelchairs.
   1. Group 2 PWC users include the population of people living with the impact of cardiorespiratory and pain, with conditions such as COPD, Congestive Heart Failure, Osteoarthritis.
   2. We agree that power seat elevation systems are reasonable and necessary for Group 2 Power Wheelchair users for performing and participating in sit to stand transfers with or without assistance, with a PT or OT evaluation and involvement by a complex rehab technology supplier (CRTS).
   3. CMS performed a comprehensive literature review on the benefits of power seat elevation systems for Group 2 PWC users, which demonstrates the benefit of the power seat elevation system in supporting the sit to stand movement to improve effectiveness and safety with this task.
   4. Notable evidence (in initial ITEM response and proposed decision summary from CMS):
      1. Burdett RG, Habasevich R, Pisciotta J, Simon SR. Biomechanical comparison of rising from two types of chairs. Phys Ther. 1985;65(8):1177-1183.
         1. Standing from a higher seat height decreases the stress in muscles surrounding the hips and knees and the range of motion needed in hips and knees to rise to the stand position. They concluded that people with lower extremity impairments, such as weakness, pain, or other disabilities, have difficulty with rising from a standard seat height.
      2. Weiner DK, Long R, Hughes MA, Chandler J, Studenski S. When older adults face the chair-rise challenge. J Am Geriatr Soc. 1993;41:6-10.
         1. Supported Burdette’s results, finding that 73-86% of older adults with STS impairments (as those who need a PWC would exhibit) needed a seat with a minimum height of 120% of the person’s knee height to execute STS successfully.

I hope the 4 main concerns and the evidence gathered above will assist with the process of making final decisions and determinations. Please feel free to reach out as needed for further information or clarification. Thank you again for your recognition that power seat elevation systems are primarily medical in nature and the opportunity to submit comments. I support Medicare’s proposal and I encourage Medicare to quickly finalize coverage of seat elevation systems to ensure that PWC users can access the care they need.

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Centers for Medicare and Medicaid Services,

I am writing to you as a doctoral occupational therapy (OT) student from Saint Joseph’s University in Philadelphia, PA. But most importantly, I am writing to you as an advocate for the community of individuals with disabilities. In the field of OT, we focus on helping individuals remove barriers to participate in their everyday meaningful activities. OTs call these everyday meaningful activities “occupations”. Occupations can encompass activities of daily living, instrumental activities of daily living, community involvement, health management, engaging in leisure, play, work, education, and social participation (AOTA, 2020). I strongly believe that approving Medicare coverage for the standing feature in power wheelchairs will not only remove financial barriers, but also enable power wheelchair users to successfully engage in their meaningful occupations. Having this feature will drastically improve the health and wellbeing of power wheelchair users.

There are many benefits and advantages for having a standing feature. For instance, a standing feature can improve the quality of life and physiological functioning in children with cerebral palsy (CP). Goodwin et al. (2017) conducted a study on the benefits of standing frames for children with CP. The results of the study showed that the participants who utilized the standing frames had improved bladder and bowel function, circulation, and breathing functions as well. Parents of the children part of this study also reported that having the ability to stand improved their children's’ motor abilities and enjoyment in activities (Goodwin et al., 2017). These benefits from standing drastically improved both the quality of life and engagement in the daily occupations of the children part of the study. By having the ability to stand, children with disabilities are better able to engage in play activities and even enjoy standing play activities with others. Thus, the standing feature is especially beneficial for children as they can feel that they are equal with their typical peers and feel included in typical children's’ activities and occupations like play and social participation.

Having the ability to stand does not only benefit children, but individuals of all ages. Arva et al. (2009) discussed the many disadvantages of being confined to a seated position in a wheelchair. When discussing physiological symptoms, it was highlighted that prolonged immobility can cause urinary tract infections, reduced bone mineral density, and increased gastrointestinal problems. This was due to the fact that being in a standing position places the pelvis in a more neutral position which leads to a more functional alignment of the spine and extended trunk (Arva et al., 2009). This simple change in position has drastic benefits for vital organs and all physiological functions. This study also discussed how standing can improve power wheelchair users’ participation in their activities of daily living. If the standing feature is covered, it can help users be able to access kitchen cabinets, countertops, reaching higher shelves, sinks, and even mirrors (Arva et al., 2009). Thus, this standing feature can help individuals engage in their instrumental activities of daily living such as meal preparation and cooking. By standing, they are able to reach the countertops and high into the cabinets to obtain items for food. Not only can the standing feature improve access to an individual’s home, but it can also improve individuals’ community and social participation. Through standing, individuals will be better able to participate in their community such as going shopping and being able to reach the hangers. Likewise, standing can help improve conversations and social engagement with others as it gives the user the ability to have eye-level conversations. This feature can also help improve social and emotional health as well because it reduces social isolation, which can inadvertently reduce symptoms of depression and loneliness. The possibilities are endless when you are able to stand.

Although this comment only discussed the benefits of standing for a few occupations, it is important to note that standing can benefit all occupations. Yet, the most important benefit of the standing feature is the amount of independence it can bring to power wheelchair users. By being able to stand, individuals will be better equipped in participating in their everyday meaningful activities with reduced assistance from others. Having this feature is so vital and important for everyone to have access to. Through this comment, I hope that you are able to see the many health benefits and improvements in quality of life that standing can bring to power wheelchair users.

Elizabeth Brown-Cordero, Occupational Therapy Student (OTS)

References

American Occupational Therapy Association. (2020). Occupational therapy practice framework: Domain and process (4th ed.). American Journal of Occupational Therapy, 74(Suppl. 2), 7412410010. https://doi.org/10.5014/ajot.2020.74S2001

Arva, J., Paleg, G., Lange, M., Lieberman, J., Schmeler, M., Dicianno, B., Babinec, M., & Rosen, L. (2009). Resna position on the application of wheelchair standing devices. Assistive Technology, 21(3), 161–168. https://doi.org/10.1080/10400430903175622

Goodwin, J., Colver, A., Basu, A., Crombie, S., Howel, D., Parr, J. R., McColl, E., Kolehmainen, N., Roberts, A., Lecouturier, J., Smith, J., Miller, K., & Cadwgan, J. (2017). Understanding frames: A UK survey of parents and professionals regarding the use of standing frames for children with cerebral palsy. Child: Care, Health and Development, 44(2), 195–202. https://doi.org/10.1111/cch.12505

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I'd like to thank CMS for the proposal to reclassify the seat elevation system to DME as a covered item.
In addition to the proposed coverage criteria for transfers, I would suggest that CMS consider the following.
Beneficiaries that qualify for a power wheelchair have lower and upper extremity limitations. These limitations prevent the beneficiary from safely and in a reasonable time perform MRADLs within their home with anything less than a power wheelchair and the power wheelchair does enable the beneficiary to get from point A to point B safely and in a reasonable time but performing ADLs doesn't end when you get to the destination. There are other challenges such as transferring in and out of the wheelchair from a bed or other higher surface as well as reach issues which can result in shoulder and neck injury. If the beneficiary attempts to stand to reach a necessary item, they are at risk of falling due to their lower extremity limitation. Falls are well documented and can lead to fractures, head injuries, etc. which usually results in hospitalization or worse. The seat elevation system will enable these individuals to safely function independently within their home. The benefits of the seat elevation system are not limited to those that qualify only for group 3 power wheelchair bases but ALL covered power wheelchairs including group 2. Please consider including in the coverage criteria group 2 power wheelchair bases, limitations with reach and fall prevention.
Thank you for your time and consideration of this very important coverage policy.

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I'd like to thank CMS for their proposal to reclassify the seat elevation system to DME as a covered item.

In addition to the proposed coverage criteria for transfers, I would suggest that CMS consider the following.

Beneficiaries that qualify for a power wheelchair have lower and upper extremity limitations. These limitations prevent the beneficiary from safely and in a reasonable time perform MRADLs within their home with anything less than a power wheelchair and the power wheelchair does enable the beneficiary to get from point A to point B safely and in a reasonable time but performing ADLs doesn't end when you get to the destination. There are other challenges such as transferring in and out of the wheelchair from a bed or other higher surface as well as reach issues which can result in shoulder and neck injury. If the beneficiary attempts to stand to reach a necessary item, they are at risk of falling due to their lower extremity limitation. Falls are well documented and can lead to fractures, head injuries, etc. which usually results in hospitalization or worse. The seat elevation system will enable these individuals to safely function independently within their home. The benefits of the seat elevation system are not limited to those that qualify only for group 3 power wheelchair bases but ALL covered power wheelchairs including group 2. Please consider including in the coverage criteria group 2 power wheelchair bases, limitations with reach and fall prevention.

Thank you for your time and consideration of this very important coverage policy.

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When it comes to participation in everyday life, most of us take our ability to stand for granted. We take for granted that we can look down at a stove as we cook our meals, that we can reach into cabinets to grab the items we need, that we can be eye level with our loved ones while having conversations, and that we can go to a grocery store and know that we will be able to do our shopping without having to ask for help in every aisle. For individuals in a wheelchair without power standing features, they don’t have the ability to do this. In fact, research has shown that for individuals who have access to power standing features, they experience positive advantages in their mental health especially when they are provided with this technology as early as possible (Bayley et al., 2020). A positive impact on mental health seems like a small reason to advocate for such big expenses to be covered, but positive mental health can lead to slower decline in physical health and better health outcomes all around. Giving someone the independence to carry out occupations for themselves, and to do occupations in the plane in which they were meant to be done is simply occupational justice. Everyone who has the cognitive ability to do for themselves, but simply cannot because they are confined to a wheelchair has the right to be provided with the technology that will allow for them to carry out their occupations as independently as possible. For that reason, Medicare coverage for seat elevation and standing systems needs to be approved today!

Kaitlyn Truitt, OTS.

Bayley, K., Parkinson, S., Jacoby, P., Cross, D., Morris, S. E., Vorster, N., Schofield, C., Kava, M. P., Siafarikas, A., Evans, K., Gaynor, O., Chiu, L., Ryan, M. M., Cairns, A., Clark, D., & Downs, J. (2020). Benefits of powered standing wheelchair devices for adolescents with duchenne muscular dystrophy in the first year of use. Journal of Paediatrics and Child Health, 56(9), 1419–1425. https://doi.org/10.1111/jpc.14963

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I am glad that Medicare is continuing to consider coverage of the seat elevation system in power wheelchairs. As someone [PHI Redacted] who is dependent upon a power wheelchair, I continue to strongly advocating for Medicare coverage of this much needed power chair function.

Seat risers assist with:
-Safer transfers- by being able to get the power chair level to the surface one is transferring to or from.

-Activities of daily living- being able to make adjustments according to the activity at hand, which will help reduce the level of difficulty, pain and fatigue. This also increases safety and independence.

-Improving quality of life and overall health- Increasing physical safety with safer transfers, increasing and/or maintaining independence by allowing better access to items that are out of reach, being physically comfortable and reducing pain and fatigue are all things that will improve a wheelchair user’s quality of life, health, and overall well-being.

Sadly, for those of us with progressive diseases our needs are only going to increase which comes at a high cost; physically, mentally and financially. Having to pay out of pocket for necessary DME is expensive. I hope that Medicare will indeed start covering this vital power chair function.

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To Whom it may concern,

I am an occupational therapist who works with patients who have neurological diseases such as ALS, MD (ex: SMA, LGMD), Spinal cord injuries, traumatic brain injuries. I am experienced our patient's unable to get the wheelchair they need due to denials. Seat elevation is very important for our patients we deem it necessary for. This can help our patient's be more independent/need less caregiver support for functional transfers to and from toilet/shower/bed with unlevel uphill, unlevel downhill, and level transfers using a slide board, stand pivot, squat pivot, hoyer/dependent caregiver transfers. The wording currently used may exclude patients from getting this neccessary seat elevation and as we see functionally will benefit and be necessary for our patients. Even if the patient is not using the seat elevation for functional transfers this will increase independence/decrease caregiver dependence with the seat elevator due to the reach needed to complete IADLs such as reaching microwave, stovetop, table top, refridgerators, cupboards and many more scenerios. I applied the work being done and the information you have already put in place to increase the ability to recieve a seat elevator. I write as I am concerned of the wording may prevent patients who need this from getting it due to wording that may exclude them. ATPs need to be continued to be a part of the team approach along with a PT or OT to identify patients who are medically necessity to receive these types of equipment. I have many patients who are dependent with their transfer but use their seate elevation to increase their comfort in society, their ability to work in their community, to interact with people in the community, and contribute to society that they would not be able to do without this seat elevation.

Thank you for your hard work in adding this into be a covered service and please consider the wording to prevent un needed denials when this seat elevation is very important for their function in other ways.

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Thank you for considering seat elevation as a meaningful and medically necessary covered Medicare item on power wheelchairs. Working in the field of assistive technology I have personally seen the impact, benefits, and reduced overall costs for caregivers and other transfer aids when seat elevate is added to a PWC. Seat elevate increases patient safety, improves functional reach for ADLs/IADLs and can be used for safe positioning and aid in safer transfers.

Seat elevate on PWCs should be considered at all evaluations for mobility for the above reasons, but unfortunately most cannot afford to pay for this option out of pocket or don't have supplemental benefits willing to cover this cost either. If Medicare paves the way in recognizing this item as medically necessary, they have the power to improve access to other funding sources for seat elevate.

When seat elevate is added an end user can reduce the need for additional transfers aids within their home, and increase overall independence with functional reaching tasks allowing reduced time caregivers are paid to spend with the patient. The benefits of increasing a person's independence and locus of control are linked to overall improved mental health well-being. A person using a PWC already faces the dilemma of increased need of support for transfers, reaching food items, cooking, grooming, and countless other tasks that increases access to their environment. I believe denying this option to users is a social injustice and further oppresses individuals who use PWCs. When applied to the PWC, I've seen immediate positive reactions in clients, they are able to elevate eye to eye to able-bodied individuals. Why should PWC users be denied this privilege? To not be looked down on. You can state that this is not "medically necessary", but I strongly disagree. Mental health is a leading safety concern in the United States. We cannot deny individuals who already face significant challenges access to this simple power wheelchair function. I ask you to consider the cost of mental health related care such as: overnight inpatient stays, medications, therapy visits and the correlation of mental well-being and healthy bodied individuals. If you consider these expenses then the cost of seat elevate is a drop in the bucket.

Seat elevate improves safety for PWC users. It allows less caregivers to assist in positioning and reduces caregiver burden and injury, it allows transfer surfaces to be level reducing fall risk to the patient (which is also a costly hospital visit along with medical emergency transport, and it improves functional reaching for the user, reducing risk of injury to the user by increasing access to items they may use a grabber for and severely injure themselves or contort in ways their body does not allow them to reach causing fractures, strains, or permanent damages to the PWC confined user. Not having power elevate doesn't prevent the human will to reach for and access something in their environment, they will find a way, and odds are it is an unsafe method of access.

There is a lot of research on motorcycle accident related deaths, but what is not always attended is PWC and motor vehicle accidents, when a user is sitting low to the ground, much lower than a standing pedestrian, they are not visible in crosswalks to vehicle drivers. I have clients on my caseload that have been struck by vehicles in crosswalks. This is preventative with seat elevate through a crosswalk, the PWC user can be as visible as a pedestrian. This should be a human right to be visible to traffic in a safety crosswalk.

Please allow us to provide this important feature to our clients, as we see safety risk first hand and are often involved in solutions and need to provide recommendations to PWC users that they can afford. Medicare has the opportunity to improve the quality of life for Individuals who need to use a PWC. For a PWC user, using a PWC is not a privilege, it is a necessity to live and to have mobility, I believe seat elevation is the same as basic mobility. It provides access that they are already denied.

Thank you for taking the time to read our comments and for considering seat elevation as a covered item. I would be happy to provide personal success stories if requested.

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Hello, my name is Jesse Wells and I'm an ATP with Choice Medical Equipment in Texas. I am in support of Medicare including power elevation for all coded power wheelchairs as a medically necessary seating function. I have seen so many patients who have completely worn out their rotator cuffs trying to transfer to surfaces that are higher than their WC seat height. We've also had our patients injure themselves by not having a power elevator, by burning themselves on stove tops because they're not high enough to reach properly. Or by falling during a transfer because the unequal height or upward motion was more than they could safely complete. Aside from improved safety around the home of cooking, transfers, opening cabinets, or turning off lights - I believe elevation greatly improves social interaction of the end user with whomever they interact on a daily basis. Patients who have elevate don't have to look at people's belly buttons all day long anymore, and if they're kyphotic in sitting posture, they don't have to strain so much to have improved visual orientation. I've seen the spirits of patients lifted and motivated just by these facts, and if that happens the quality of life is improved, which I believe is a legitimate consideration of justifying elevation as medically necessary.

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Imagine trying to live your life at home and in the community at one level in a power wheelchair which a normal sitting height which is approximately 18" to 20" from the floor. Many things you need to access safely are out of reach, therefore your need help and can not do it for yourself. Also imagine trying to transfer from one surface to another and the height it always different thereby making the transfer harder and unsafe. Now add a seat elevation system which can raise you up 12" and suddenly everything changes and improves your function and safety and confidence.

By covering seat elevation on GP 3 pwc's hundreds if not thousands of people living with disabilities will benefit with improves lives.

Please add coverage of seat elevation to the Medicare plan. Thank You!

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I am a 59 year old Permobil powered wheelchair user. My current wheelchair only has limited Seat Elevation with Active Reach which allows only a 30 degree range of incline, but without the ability to move freely around the room in comparison to my first and second Permobil wheelchairs which included full standing and seat elevation features which allowed free movement around the room. I have greatly missed having the full Standing and Seat Elevation features and abilities in subsequent wheelchairs and would strongly encourage CMS to allow them to be covered as standard options available to everyone in the future.

Now, that I’m an older adult, living independently in the community, it has become more difficult for me to find attendants who are physically able to help me stand and ambulate as my doctors want me to be weightbearing several times a day for extended periods of time.

Having a powered wheelchair that can stand me up and hold me in the proper positioning in an upright position for an extended period of time will not only increase my bone density, but will help shift my weight off pressure points, improve my ability to breathe more deeply, improve my muscle tone, reduce my muscle spasticity, improve my digestion, improve my bowel and bladder functioning, reduce edema, lesson my constipation and improve my circulation, all without placing me at risk for injury.

[PHI Redacted]

Having the Powered Standing System with the Power Elevating Seat will enable me to independently stand and move around the room safely while in a standing position, thereby giving me greater independence and the ability to lead a more inclusive and more productive life as I carry-out many of my volunteer activities and my activities of daily living from a standing upright position and not a sitting down position. Adding the standing features to my next powered wheelchair will afford me greater opportunities to become weightbearing and it will do so more easily, more safely and more often, no matter my location.

RESNA, the Rehabilitation Engineering and Assistive Technology Society of North America, which is the premier professional organization dedicated to promoting the health and well-being of people with disabilities through increasing access to technology solutions, fully supports the medical necessity of Powered Standing Systems and Power Elevating Seat devices. (RESNA Home Page, http://www.resna.org/)

In the past, I have appealed denials of Powered Standing Systems and Power Elevating Seat devices all the way up to the Administrative Law Judge (ALJ) level and won! However, I do not believe that persons with disabilities should be forced through numerous appeals in order to get what we so desperately need in order to have improved health and quality of life.

In summary, I feel that Powered Standing Systems and Power Elevating Seat devices are Medically Necessary (as precedent has already been established by the ALJ) and therefore should be covered as standard options available to all persons under the CMS guidelines for powered wheelchairs.

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As a Complex Rehabilitative Technology Supplier (CRTS), I am writing to express my strong support for the inclusion of seat elevation systems as an accessory to Group 3 power wheelchairs under the Medicare program. In particular, I would like to highlight the benefits of seat elevation systems in relation to transferring patients.

Transferring patients in and out of wheelchairs is a task that is often challenging and physically demanding, both for the caregiver and the patient. The use of seat elevation systems can greatly facilitate this process by raising the height of the seat and bringing the patient to a more convenient and accessible height for transfers. This can reduce the risk of injury to both the patient and the caregiver by minimizing the need for awkward bending or lifting postures.

Moreover, seat elevation systems can provide additional benefits in the context of transfers. For instance, when a patient is at a higher level, it may be easier to align their center of gravity with that of the caregiver, facilitating smoother and more stable transfers. Additionally, being at a higher level can give patients greater visibility and control over the transfer process, increasing their sense of independence and reducing anxiety.

Despite the significant benefits of seat elevation systems for transferring patients, they are not currently covered by Medicare as an accessory to Group 3 power wheelchairs. This exclusion means that many patients are unable to access these essential systems due to the high cost of purchasing them out-of-pocket.

I urge the Centers for Medicare and Medicaid Services to consider including seat elevation systems as an accessory to Group 3 power wheelchairs under the Medicare program. By doing so, many patients will be able to access these vital systems, enabling them to enjoy improved safety, independence, and quality of life.

Thank you for your consideration of this important matter.

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Seat Elevation is one of the top medical necessary options that have been invented over thirty years ago. It truly allows the user to be and stay independent whether they are transferring into or out of a bed along with transferring on and off a toilet safely. It also helps with the ability to raise the seat elevator to safely cook on a stove or reach into the refrigerator. The fact that this device has been around and used for over 30 years goes to the fact that it is not a product that people want but a product that people truly need and it provides a tremendous amount of safety.

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Good afternoon,
I have been working to get resident's in LTC facilities specialized seating for over 3 years. SNF's are expected to provide the most basic seating for resident's however this limits their independence and quality of life when no provided a more specialized, custom wheelchair. Those who have been approved for more specialized mobility have demonstrated more independence and have expressed more freedom and happiness being able to complete their mobility without any assistance. Please continue to assist these residents in maintaining and continuing their independent mobility and way of life in long term care settings.

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Hello,

My name is Deborah Powers and I am an occupational therapy student (OTS), at Saint Joseph's University. Upon learning of the proposed decision to offer Medicare coverage for seat elevation systems in power wheelchairs, I found this to be not only to be important to those who require these systems, it is deserved. Everyone deserves to be afforded the opportunity to engage with those around them and their surrounding environments. Engagement is what we as occupational therapy practitioners do—help our patients engage in what matters to them as an individual. This is what the individual wants to do, needs to do, and is required to do. That is occupation.

Occupations, especially for individuals who require power wheelchairs, include functional mobility, community mobility, social participation, work, play, education, and leisure. Leisure is an occupation that I like to set high on the list of priorities for those I have worked with and will be working with in the future.

The benefits of powered standing wheelchairs/wheelchair seat elevation systems positively impact leisure activities. According to Ding (2008), seat elevation systems improve stability, maintain comfort, and reduce seating pressure. Elevation, tilt-in space, and power standing allows for equity and inclusion when doing the occupations that matter for an individual. This could be going to dinner with friends in a busy restaurant for social participation, partaking in self-care tasks at the bathroom vanity, traveling, crafting for leisure in a workspace or within the home, anything imaginable. This can be achieved with this decision to offer these possibilities through Medicare.

I urge you to consider moving forward with the proposal to offer standing systems and seat elevation systems through Medicare. Everyone deserves to participate and engage with the world around them. With this, it can be achievable.

Thank you,

Deborah Powers, OTS

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I strongly recommend you consider covering power elevate for group 3 wheelchairs. As a wheelchair technician and ATP for over 10 years, the amazing benefits of having greater access to your environment, increased independence, as well as the social and psychological benefits for adults and developing children; Please do not restrict it just to those who can transfer themselves independently. There are many people that can still benefit greatly from the added access and freedom in their environment, Especially when it comes to children who are developing social skills with family, classmates and new people coming in to thier lives.

Thank you for your time and consideration.

Sincerely,

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Occupational Therapy Student
It is a huge step in the disability community that Medicare coverage can be offered for seat elevation systems for power wheelchair users. My name is Makenzi Kauffman and I am currently an occupational therapy student and have learned through personal experience and within my schooling the importance of enabling engagement in everyday, meaningful activities and the influence that has on the overall quality of life and well-being for both nondisabled and disabled individuals. I believe Medicare should finalize its proposal to cover seat elevation systems in power wheelchairs for Medicare beneficiaries with mobility disabilities to enhance the accessibility and improve engagement in everyday activities for wheelchair users that are unable to afford this technology. There are many health and functional benefits to these systems and standing is critical to various areas of occupation including work, leisure, social participation, and areas of activities of daily living (ADL’s) and instrumental activities of daily living (IADL’s) performed in the home. According to (Paleg & Livingstone, 2015), adults sitting more than 8 hours a day can experience “painful, problematic and costly secondary complications” which influence their overall health and can require a caregiver to assist in daily tasks (p.2). By using elevation systems, individuals will be more enabled to participate in their ADL’s in the home including grooming tasks, toileting, and feeding more independently by giving them access to things that were previously unable to be reached. Elevation systems can aid in a reduction of pressure ulcers and spasticity, and the technology can facilitate emptying of the bladder which can increase their independence in toileting tasks (Nordström et al., 2013). Standing devices can enable engagement in occupations such as work and leisure as well by providing the individual with a more diverse range of options in these occupations, while positively impacting their confidence in what they can achieve and engage in without limitations. I want to say thank you to Medicare for allowing me to submit a comment in regards to this coverage and I want to restate my support in this passage as it will promote engagement in everyday occupations and meaningful activities for the disabled community everywhere. I encourage you, Medicare, to finalize this coverage of seat elevations and more towards standing systems as quickly as possible so wheelchair users are able to access the care they need.

Nordström, B., Näslund, A., Eriksson, M., Nyberg, L., & Ekenberg, L. (2013). The impact of supported standing on well-being and quality of life. Physiotherapy Canada, 65(4), 344–352. https://doi.org/10.3138/ptc.2012-27
Paleg, G., & Livingstone, R. (2015). Systematic review and clinical recommendations for dosage of supported home-based standing programs for adults with stroke, spinal cord injury and other neurological conditions. BMC Musculoskeletal Disorders, 16(1). https://doi.org/10.1186/s12891-015-0813-x

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