USSAAC Advocacy Alert: Medicare SGD Reporting

The issue:

SGD manufacturers have been giving heightened scrutiny to SLP reports for Medicare SGDs. Specifically, they have been raising questions about intended SGD uses outside the client's home. Out of home SGD use has never been a concern before. Obviously, SGDs are intended to be portable and come and go wherever the client's need to communicate will arise.

 

Background:

This issue originates with a provision of the Medicare law says "durable medical equipment includes iron lungs, oxygen tents, hospital beds and wheelchairs .... used in the patient's home...." 42 USC 1395x(n). To date, "used in the patient's home" has been applied only to wheelchairs and other mobility equipment. Medicare uses it as a medical need limitation: it will only review facts related to medical need that arise within the patient's home. Once the device is found medically necessary based on “in the home” need and provided, there is no further limitation on actual use of a device in the community. It appears Medicare will now apply “used in the patient’s home” to SGDs. In practical terms, Medicare will no longer look at the client's communication needs arising out of the home as evidence of medical need for the SGD.

 

Suggested Response: "Color within the lines."

SLPs should limit the discussion of intended SGD uses in their reports to communication opportunities that will arise in the client's home. Intended face-to-face communication with the client’s spouse, caregivers, friends, services providers, visitors, etc., should either not refer to any location, or refer to the communication arising at the client’s home. Intended telephone, email and text uses also should be discussed with no location stated or as originating while the client is at home. These examples enrich SLP conclusions that clients need the SGD: they should continue to be included.

 

SLPs should not include information in the report about intended SGD uses that will arise outside the home, e.g., participating in religious services; community-based meetings; visiting at the homes of friends or family; communicating at health care appointments. Do not include information about SGD features that will be needed only outside the home.

 

Expected Effects of “In the Home” Focus: none.

Following these suggestions should have no effect on clients’ ability to get the most appropriate SGD to meet their needs and no effect on their ability to use their devices in any location. Also, SLPs have been editing their SGD reports for years to conform their reports to funding programs’ requirements.

 

For Medicare, we have had the ability to unlock devices for years, but SLPs have been instructed never to discuss those intended uses in their reports. For Medicaid and insurance, SLPs have been writing reports for school age children for years, but have been instructed to never write about use of the device to aid school tasks other than communication, or about how the device might be used unlocked.

 

Those acts do not affect device recommendations, and once devices are approved, they do not affect the client's freedom to use the device any way s/he wants. The same will be true here.

 

A Final Comment: Funding reports are intended to show funding sources that the request satisfies what the funding source will base its decision on. Accordingly the content must address what the funding source requires and should NOT include information the funding source does not require. Funding reports are clearly distinguished from treatment notes, which should include a comprehensive review of all relevant facts.

 

Only when a funding source imposes limitations that affect device choice and make it impossible to recommend the most appropriate device is push back from our community appropriate or necessary.

 

Lew Golinker Lewis Golinker, Esq. Advocacy Director, USSAAC

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