NCHR Comments on the CMS National Coverage Analysis of Seat Extenders for Wheelchairs

September 14, 2022

The National Center for Health Research (NCHR) appreciates the opportunity to provide public comments on the Centers for Medicare and Medicaid Services (CMS) National Coverage Analysis regarding the coverage of seat extenders associated with Group 3 powered wheelchairs. As a nonprofit think tank that conducts, analyzes, and scrutinizes research on a range of health issues, we have a particular focus on which prevention strategies and treatments are most effective for which patients and consumers. Our aim is to ensure that healthcare consumers are equipped with information that can help them access quality, evidence-based medical products to improve their health and quality of life. We strongly support the coverage of these seat extender systems through Medicare and encourage you quickly act on this decision.

A seat elevation system is often necessary for people living with spinal cord injuries and other mobility impairments to become independent in their mobility-related activities of daily living (MRADLs), which include toileting, feeding, dressing, grooming, and bathing. These systems allow for safe transfers between surfaces at different heights (e.g., beds, toilets, vehicles, etc.). Without a seat elevation system, numerous injuries have been reported during transfers, including fractures and head injuries.1 Research has also shown how seat elevation systems can reduce potential injuries to caregivers during transfers, by allowing individuals to lift to the correct height prior to movement.2 It is essential that individuals are at the right level prior to transferring to reduce the biomechanical stress placed on the caregiver.3

There are numerous direct medical benefits from the use of power seat elevation systems in power wheelchairs. Many preventable complications and secondary conditions are common among individuals who spend long periods of time unable to stand or walk, restricted to a bed, chair, or wheelchair. Pressure ulcers are the most common preventable long-term medical complication following a traumatic spinal cord injury.4 These injuries could be substantially reduced by giving individuals the ability to change position as needed without the assistance of a caregiver. There are also physiological benefits associated with standing, including improved circulation and overall cardiovascular function.5 There are also mental health benefits to patients and caregivers when an individual with limited mobility is less dependent on others, including improved quality of life and well-being.6 Increased access to seat elevation systems through Medicare coverage would greatly improve the health of millions of beneficiaries.

  1. Xiang, H., Chany, A. M., & Smith, G. A. (2006). Wheelchair related injuries treated in US emergency departments. Injury prevention12(1), 8-11.
  2. Santaguida, P. L., Pierrynowski, M., Goldsmith, C., & Fernie, G. (2005). Comparison of cumulative low back loads of caregivers when transferring patients using overhead and floor mechanical lifting devices. Clinical Biomechanics20(9), 906-916.
  3. Wiggermann, N., Zhou, J., & McGann, N. (2021). Effect of repositioning aids and patient weight on biomechanical stresses when repositioning patients in bed. Human Factors, 63(4), 565-577.
  4. McKinley, W. O., Jackson, A. B., Cardenas, D. D., & Michael, J. (1999). Long-term medical complications after traumatic spinal cord injury: a regional model systems analysis. Archives of physical medicine and rehabilitation80(11), 1402-1410.
  5. Saeidifard, F., Medina-Inojosa, J. R., Supervia, M., Olson, T. P., Somers, V. K., Prokop, L. J., … & Lopez-Jimenez, F. (2020). The effect of replacing sitting with standing on cardiovascular risk factors: a systematic review and meta-analysis. Mayo Clinic Proceedings: Innovations, Quality & Outcomes4(6), 611-626.
  6. Nordström, B., Näslund, A., Eriksson, M., Nyberg, L., & Ekenberg L. (2013). The impact of supported standing on well-being and quality of life. Physiotherapy Canada, 65(4), 344-52.