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October 3, 2003
Tom Scully
Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Room 314G Hubert Humphrey Building
200 Independence Avenue, S.W.
Washington, DC 20201
Re: Request for Meeting Regarding CMS 10-Point Plan and OIG Investigation
to Combat Fraud and Abuse in the Power Wheelchair Benefit Under Medicare
Dear Mr. Scully:
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 services
for people of all ages with disabilities and chronic conditions.
The ITEM Coalition welcomes the federal government’s 10 point-initiative
to combat fraud and abuse in the purchase of power wheelchairs under Medicare’s
durable medical equipment benefit, as scarce 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 the
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 even in cases with ample
documentation supporting the need for motorized devices.
Additionally, representatives of the ITEM Coalition request a meeting with
you to discuss the involvement of beneficiaries and their advocates in
promoting a better understanding of Medicare coverage criteria and appropriate
access to needed technologies. The need for the Center for Medicare and
Medicaid Services (CMS) to revise its coverage policies as part of the
anti-fraud initiative presents an opportunity to revisit its current coverage
policies in light of contemporary medical standards and social mores and
to update them to prevent persons from being isolated in their homes.
Thank you for your initiative to reduce fraudulent claims under the Medicare
power wheelchair benefit. We look forward to working closely with you to
ensure that the final outcome results in more available funds for legitimate
claims and improves access to rehabilitation equipment for beneficiaries.
We will be in touch with your office soon to schedule a meeting. Please
do not hesitate to contact at me at (202) 429-7694 or LeeP at pva.org on
behalf of the ITEM Coalition Steering Committee members listed below if
you have any questions regarding this letter. 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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