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In May 2024, the Centers for Medicare and Medicaid Services implemented changes to the five-year replacement rule for power mobility devices, effective June 2, 2024.¹ Published in June 2025, the update eliminates the mandatory clinician evaluation at the five-year reasonable useful lifetime if equipment is replaced with the same HCPCS code (health care common procedure coding system) as the prior device.

At first glance, this change appears to reduce administrative burden and streamline access. However, the policy shift raises critical concerns across the Complex Rehabilitation Technology community with respect to clients’ best interests and long-term outcomes. By removing the clinical evaluation requirement, the rule risks undermining best practices, compromising client safety and increasing long-term health care costs. 

This policy change raises a central question for the CRT community: What role should clinicians play in the replacement of power mobility devices? While the Center for Medicare and Medicaid Services suggest efficiency can be gained by removing their involvement, decades of best practice show that the clinical evaluation remains the cornerstone of safe and appropriate equipment provision.

The clinical evaluation is not a formality; it is foundational to CRT provision.^2-5 A licensed clinician identifies an individual’s health status, function, daily activities, environments and goals, and then prescribes equipment features best suited to meet those needs.^4-5 Suppliers play an equally critical and complementary role by matching technology options to the clinician’s recommendations.⁵

RESNA emphasizes this shared responsibility: “The participation of both the therapist and supplier is critical, as they possess different and complementary skill sets.”³ Without this dual perspective, the process risks devolving into a payer-centered transaction focused on codes rather than people.

What RESNA calls critical, the new policy treats as optional, leaving it to clinicians and suppliers to defend the role of comprehensive evaluation in protecting users’ health and independence. Eliminating the clinical evaluation shifts medical decision-making to suppliers, placing them in a role that may exceed their scope of practice.⁶

While suppliers are highly skilled in product knowledge, many are not medically trained to assess clinical factors such as cognition, strength, range of motion, balance, coordination, posture, skin integrity, history of pressure injuries, pain, endurance and cardiovascular status, which are core standards of a comprehensive clinical Complex Rehab Technology assessment.⁴ Even when the supplier-ATP also has medical training through a physical therapy or occupational therapy degree, it is not their role in CRT provision to perform the medical assessment.⁷ 

At the same time, CRT suppliers face significant pressures to process orders quickly.⁸ When combined with the policy change, this pressure can create predictable shortcuts: Less ethical suppliers may default to the same HCPCS codes to avoid delays. What appears “efficient” on paper can instead create significant risks for clients. Several risks emerge as a result:

• Scope creep: Suppliers risk acting outside their scope of practice by determining medical necessity after five years.⁶
• Code inertia: Pressure to keep the same HCPCS codes for speed and competitiveness, even when client needs have changed.
• Reduced choice: Without a clinical assessment, clients lose opportunities to explore new features or technological advances.
• Delayed access: Clients may be deprived of medically necessary equipment when changes require new codes and a clinical evaluation.
• Potential abuse: Some suppliers could automatically cycle equipment every five years or steer clients toward higher-margin products without medical justification.

These risks are amplified by the fact that most clients’ needs change significantly over time. Some experts estimate that up to 80% of end users require equipment modifications within a five-year period.⁹ Even those with relatively stable conditions may develop pain, skin breakdown or shifts in caregiver support that alter their requirements. Progressive conditions accelerate these changes further.

Moreover, devices under the same HCPCS code are not interchangeable. For example, two skin protection cushions may share a code but differ dramatically in materials and pressure relieving properties. Only a clinician trained in CRT, working in partnership with the supplier’s product expertise, can ensure the chosen equipment meets the client’s medical and functional needs. Without reassessment, clients risk receiving suboptimal, outdated or unsafe equipment simply because it is quicker to process.

The CRT field has long-championed person-centered care. Evidence shows that comprehensive clinical assessments improve user-technology matches, increase satisfaction, reduce abandonment and lower overall health care costs.^3,10-13

By eliminating the clinical assessment requirement, the new rule signals that best practice and person-centered care is optional—or merely a bureaucratic formality. This stands in direct opposition to national and global benchmarks such as the 2023 WHO Wheelchair Provision Guidelines,^3,13,14 which affirm that a comprehensive clinical assessment is indispensable to safe, effective and person-centered CRT provision.

To preserve best practice while addressing industry goals of reducing administrative burden and maximizing efficiency, the Clinician Task Force recommends the following adjustments:

• Require a clinical assessment for all five-year replacements, even when HCPCS codes remain unchanged.
• Allow streamlined documentation at the five-year mark when minimal or no changes are identified, provided the evaluation is performed by a specialty clinician with ATP or ATP/SMS credentials.
• Strengthen collaboration with advocacy organizations to ensure safeguards are in place and to protect clients from potential misuse.
• Pursue administrative simplification in other areas, such as reducing duplicative face-to-face requirements or creating a faster approval pathway when the assessment has already been completed by an ATP-certified clinician.
• Clarify CMS policy language to eliminate ambiguity. Some suppliers and clinicians remain uncertain whether evaluations are optional or required.

This is not a regulatory technicality. At stake are independence, safety and quality of life for people who rely on CRT. Without reassessment, clients may face preventable complications — falls, pressure injuries, pain, reduced function and avoidable hospitalizations. These outcomes drive up costs rather than reduce them.

Policy should reduce paperwork, not eliminate safeguards. A five-year-old wheelchair prescription is no more reliable than a five-year-old eyeglass prescription. Codes may remain the same, but people change. We would never accept outdated prescriptions for medications, oxygen or hearing aids. CRT deserves the same standard of care.

Reducing barriers is a positive goal, but not if it opens the door to waste, abuse and unsafe outcomes. CMS’ intent to ease administrative burden is commendable, but efficiency cannot come at the expense of best practice. Eliminating the clinical evaluation risks shifting decision-making outside clinical expertise- limiting client choice and undermining safety.

The CRT community must continue to advocate for policies that put people before paperwork. Every five years, a clinical reassessment remains the gold standard to ensure equipment — whether identical, modified or new — meets client needs. Reinforcing the reassessment as essential, while trimming redundant hurdles, is the best path to clinically defensible, timely, safe and person-centered access to mobility technology.

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Amber may be reached at amber.ward@advocatehealth.org.

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References:

1. CGS Medicare. Prior Authorization for Replacement of PMDs – Effective May 9, 2024; revised June 2, 2025.
2. Lange ML, Minkel JL, eds. Seating and Wheeled Mobility: A Clinical Resource Guide. 2nd ed. 2025.
3. RESNA. Wheelchair Service Provision Guide. 2011.
4. Clinician Task Force. Clinician Checklist for CRT Evaluations. 2021.
5. Waugh K. Problem-solving model for seating assessment and product feature analysis. Presented at: International Seating Symposium; March 2025; Pittsburgh, PA.
6. RESNA. Code of Ethics and Standards of Practice. 2023.
7. RESNA. Disclosure Guidelines: Usage of the Assistive Technology Professional (ATP) Designation. 2009.
8. Breaux R. Stakeholder perceptions of policies, processes, and their implications in the provision of complex rehabilitation technologies: a qualitative study. Disabil Rehabil Assist Technol. 2025:1–17.
9. Beaulieu L. CMS simplifies replacement wheelchair rules. HME News. July 18, 2025.
10. Cohen L, Greer N, Berliner E, Sprigle S. mobilityRERC State of the Science conference: considerations for developing an evidence base for wheeled mobility and seating service delivery. Disabil Rehabil Assist Technol. 2013;8(6):462–471.
11. Federici S, Corradi F, Meloni F, Borsci S. Successful assistive technology service delivery outcomes from applying a person-centered systematic assessment process: A case study. Life Span Disability. 2015;18(1):41–74.
12. Verza R, Carvalho MLL, Battaglia MA, Uccelli MM. An interdisciplinary approach to evaluating the need for assistive technology reduces equipment abandonment. Mult Scler J. 2006;12(1):88–93.
13. World Health Organization. WHO Wheelchair Provision Guidelines. 2023.
14. Hon BA. Clinical reasoning & competency in wheelchair prescription. Directions. 2021;3:20–29.