In late December, ACI Alliance and several of our State Champions submitted comments to the Centers for Medicare and Medicaid Services asking that the US Department of Health and Human Services further clarify the definition of Rehabilitation and Habilitation services under the Essential Health Benefit (EHB) of the Affordable Care Act. Similar comments were sent to the US Office of Personnel Management. Given that appropriate and adequate coverage of cochlear implants can make a critical difference in the lives of individual Americans with severe to profound hearing impairment, the ACI Alliance recommended the following for inclusion in the final rule.
Prohibit unreasonable and arbitrary visit and dollar limits on a specific category of benefits such as follow-up audiology or therapy services. ACI Alliance found that most ACA plans limit the number of therapy visits to 30 per year. Further, plans plans should not place arbitrary limits on devices which prevent a patient from receiving the accepted and recognized standard of care appropriate for that benefit. For example, limiting a device benefit to one device per year would prevent a child with profound hearing impairment from receiving bilateral cochlear implants, which are now the standard of care for children with profound hearing loss to allow them to develop language that is as close as possible to that of their typically hearing peers.
Cover device maintenance, including replacement batteries and long-term maintenance of external devices even after a device warrantee runs out. With regard to CI, the replacement of processors is a prime example of the need for the coverage of device maintenance under the EHB.