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October 6, 2003
Dara Corrigan
Acting Principal Deputy Inspector General
Office of Inspector General
Department of Health and Human Services
Room 5541 Cohen Building
330 Independence Avenue, S.W.
Washington, D.C. 20201
Re: CMS 10-Point Plan and OIG Investigation to Combat Fraud and Abuse in
the Power Wheelchair Benefit Under Medicare
Dear Ms. Corrigan:
This letter is submitted on behalf of a national, consumer-led coalition
known as the “ITEM” Coalition, which is an acronym for Independence Through
Enhancement of Medicare and Medicaid. The ITEM Coalition was formed in
2003, and its over 70 member organizations include a diverse set of disability
organizations, aging organizations, other consumer groups, labor organizations,
voluntary health associations, and non-profit provider associations. The
ITEM Coalition’s purpose is to raise awareness and build support for policies
that will improve access to assistive devices, technologies and related
services for people of all ages with disabilities and chronic conditions.
The ITEM Coalition welcomes the federal government’s 10-Point Plan to combat
fraud and abuse in the purchase of power wheelchairs under Medicare’s durable
medical equipment benefit, as scare resources are needed to promote beneficiary
access to much needed rehabilitation equipment and assistive technologies.
At the same time, we urge your caution in implementing this anti-fraud
and abuse initiative to prevent unintended consequences and inappropriate
denials of legitimate claims. We are concerned that well-meaning efforts
to root out fraud and abuse may lead to coverage denials or significant
delays in obtaining necessary equipment even in cases where ample documentation
supporting the need for power mobility devices exists.
To prevent harm to beneficiaries, we urge the OIG to closely monitor and
study the impact that CMS’s 10-Point Plan and the OIG’s enforcement efforts
have on legitimate beneficiary access to power mobility devices.
Thank you for your initiative to reduce fraudulent claims under the Medicare
power wheelchair benefit. Every dollar saved on fraudulent and abusive
activity can be devoted to meeting existing and future needs of beneficiaries
with disabilities and chronic conditions.
Sincerely,
Lee Page
Paralyzed Veterans of America
ITEM Coalition Steering Committee Member
Other Steering Committee Member Organizations
American Foundation for the Blind
Advancing Independence: Modernizing Medicare and Medicaid
Consortium for Citizens with Disabilities Health Task Force
Medicare Rights Center
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