It is time to submit responses to the CMS new National Coverage Determination (NCD). The NCD is the national Medicare policy that defines SGDs and requires the SGD to be a dedicated device used solely by the individual with the medical need. For example, Medicare will reimburse for software that allows a computer or tablet to function as an SGD, but will not provide reimbursement for the computer or tablet. On November 9, CMS rescinded the rules requiring SGD’s be locked and dedicated, but they requested a period of public comment until December 6. There are other points that that need to be addressed that were in the recent NCD, including capped rental, but this comment needs to focus on the changed policy, along with emphasis on eye-gaze technology. To facilitate your comment, I have attached below eight comment areas that were developed and delineated by an expert panel called the Medicare Implementation Team, an ad hoc group of AAC clinicians, researchers, advocates, educators, manufacturers, and other experts and stakeholders, many of whom worked on the 2001 NCD, and recognize the changes that have occurred in technology use since the document was drafted. I made some minor changes in the wording, since other organizations and agencies may be using these paragraphs. Please utilize the introductory paragraph, along with personalization, then copy and paste the eight comment sections, with any additional comments you may wish to add. Personal stories of clients whose lives have benefited or pivoted on the use of SGD’s would make your comment stand out. Please enter them next to the corresponding comment. (We recommend that you get the client’s permission if you wish to include their name. Otherwise, please use initials.) Here is a video FAAST produced along with Michael Phillips from Tampa on access to SGDs being a Right. https://youtube/watch?v=8oi1mK4RqjQ CMS recognizes the number of comments as a major pertinent metric and so far only 200 comments have been submitted. It is our time to be a major participant in this advocacy endeavor. A tip of the hat to Board member Carol Zangari and Atlantic RDC’s Jennifer Kent Walsh and Nancy Harrington for their help in bringing additional information from the ASHA (American Speech-Language Hearing Association) conference. Here are the steps to submitting your written statement, courtesy of patientprovidercommunication.org : Review and Edit the Sample Comments section. I have included them in the two attached files. One is a Microsoft Word file and the other one is a Rich Text file. Please include any individual or personal stories you might have. Copy the edited Sample Comments section with your personal revisions. We recommend pasting the eight comments to a Word Document first so you can add personal information and experiences that strengthen your submission and then paste those into the comment section. You may wish to select fewer of these comments, or only one, if you want to concentrate your personal comments on a particular point. Also, you can submit several times, each with the focus on one comment, or just a few comments. Click here to visit the CMS website in a new window. Before you will be allowed to enter any text, you will need to click the link to view the CMS PHI Posting Policy. Another window will open detailing the positing policy. Then check the box next to the statement: “I have read and understand the CMS policy regarding redaction of PHI” Fill in the form on the CMS website. PASTE your comments to the Comment box. The fields with the red asterisks are mandatory! When you are satisfied with your comments, click the orange SUBMIT button at the lower right corner of the page. Your comments will not be recorded until you click SUBMIT! Any help is as always, greatly appreciated. Michael Daniels and Gary J Stein . Michael J. Daniels FAAST Executive Director 3333 W Pensacola Street Building 100 Suite 140 Tallahassee, FL 32304 Phone: 850-487-3278 Ext. 102 Mobile: 850-766-3732 Fax: 850-575-4216 Please Note: Florida has a very broad public records law. Most written communications to or from FAAST staff regarding organization business are public records available to the public and media upon request. Your e-mail communications may therefore be subject to public disclosure. FAAST is a fragrance-free workplace. Thank you for not wearing any of the following during your visit: cologne, after shave lotion, perfume, perfumed hand lotion, fragranced hair products, and/or similar products. Our chemically-sensitive co-workers and clients thank you
Posted on: Wed, 03 Dec 2014 23:10:56 +0000
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