SECTION 1:
Overview of Formal Request For National Coverage Decision
For Augmentative And Alternative Communication Devices

 

Nature of Request:

This Formal Request seeks Medicare coverage of Augmentative and Alternative Communication (AAC) devices. These devices treat certain individuals with severe communication impairments, such as dysarthria, apraxia, and aphasia, attendant to motor disorders and such neurologic conditions as amyotrophic lateral sclerosis (ALS or Lou Gehrig’s disease), cerebral palsy, Parkinson disease, locked-in syndrome, multiple sclerosis, and traumatic brain injury.

Current Medicare and Medicaid Coverage Status of AAC Devices:

The Medicare Coverage Issues Appendix, at an unknown point in time, labeled AAC devices as ‘communicators’ -- not an appropriate term -- and classified them as noncovered convenience items. The Health Care Financing Administration (HCFA), through the Freedom of Information Act, has acknowledged that it has no documentation of the types of devices considered or the basis for the noncoverage decision. In contrast, every Medicaid program covers AAC devices, either as durable medical equipment or prosthetic devices, or as necessary equipment within the speech-language pathology benefit category.

FDA Status:

Since 1983, the Food and Drug Administration (FDA) has classified AAC devices as ‘powered communication systems.’ 21 C.F.R. § 890.3710.

Estimated Total Prevalence of AAC Device Need Among Medicare Beneficiaries:

47,000 individuals.

Requested Benefit Category and Payment Classification:

AAC devices appropriately are classified as items of durable medical equipment (DME), which are routinely purchased. They meet the specific regulatory criteria necessary for DME coverage (they can withstand repeated use, serve a medical purpose of treating severe communication disabilities, are not useful in the absence of illness or injury, and are appropriate for home use), as well as the Medicare reasonable and necessary statutory standard, by permitting individuals with severe dysarthria, apraxia, or aphasia to communicate.

Requested Codes:

The HCPCS Alpha-Numeric Editorial Panel issued Code E1900, effective January 1, 2000, for a ‘speech communication device,’ with the following descriptor: ‘synthesized speech augmentative communication device with dynamic display.’ However, the universe of AAC devices is best covered by three codes, as follows:

Code 1: AAC Devices with Digitized Speech Output

Code 2: AAC Devices with Synthesized Speech Output which (a) Require Message Formulation by Spelling, and (b) Require Access by Physical Contact Direct Selection Techniques

Code 3: AAC Devices with Synthesized Speech Output which Permit Multiple Methods of Message Formulation and Multiple Methods of Access. (This code will include all AAC devices covered by HCPCS Code E1900.)

Codes for Accessories: access technologies; mounting systems; supplemental power sources; carrying cases; and software.

Modifiers for Code 1

Requested Coverage Criteria:

HCFA should require an assessment by a qualified speech language pathologist before Medicare coverage of an AAC device would be deemed appropriate, with the determination of the appropriate device based on nine clinical criteria:

    1. Communication disability with a diagnosis of severe dysarthria, apraxia, and/or aphasia
    2. Communication needs that cannot be met using natural communication methods
    3. Need for speech output communication device to meet specified functional communication goals
    4. Linguistic capability for independent language (messages) formulation
    5. Most efficient and effective technique for message production is spelling
    6. Need for a device with extensive language storage capacity and rate enhancement features
    7. Most efficient and effective access technique is via physical contact direct selection
    8. Most efficient and effective access technique is via an electronic accessory permitting direct selection
    9. Most efficient and effective access technique is via indirect selection (e.g., scanning, Morse Code)

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