Justify Paying for WC19 Wheelchairs and Seating

For the foreseeable future, the “transit option” will be considered an “upgrade” or “add on” to the basic manual or power wheelchair. The transit option refers to a successfully crash-tested manual or power wheelchair frame and seating system (i.e., it complies with the voluntary industry standard RESNA WC19). The visible differences are the inclusion of 4 marked attachment points for the 4-point strap securement and a wheelchair anchored safety belt. The wheelchair frame, the attachment points and the pelvic belt have all passed a 30mph/20g sled test.

Wheelchair transportation safety standards are still voluntary industry standards rather than Federal or state regulation. The Food and Drug Administration have not yet recognized the importance of incorporating these industry standards into mandated design criteria for all wheelchairs approved for sale in the US. Additionally, the coding body of the Centers for Medicare and Medicaid Services (CMS) does not require it. Even more lobbying and political activism along with injury and mortality data are needed to create this policy change.

In the meantime, payment for transit options on wheelchair must be requested on a case-by-case basis. Therapists and Rehabilitation Technology Suppliers (RTS) who help clients choose new wheelchairs must justify the need for an accessory or feature when it is not part of a basic wheelchair. Currently, efforts are focused on urging therapists and suppliers to consider transportation when specifying new wheelchairs. In addition, they need to educate clients or their family members about the value of WC19 wheelchairs.

Cut and Paste: Put into Letters of Justification

The following statements are offered as a resource for statements to cut and paste into clinical reports and letters of justification. Documenting the client’s need for a WC19 wheelchair may require new language for the average clinician or supplier. Keep in mind that you will need to combine, modify and personalize the following statements:

Transportation in the larger community is important for this client because they:

  • Must travel to and from work on a daily basis. They spend about ____ min/day in this high-risk activity.
  • Must travel to and from school on a daily basis. They spend about ____ min/day in this high-risk activity.
  • Are active in the community and must be able to travel in all types of vehicles including public transportation. They spend about ____ hours/week in this high-risk activity.
  • Must frequently travel to medical and therapy appointments in the community and travel using paratransit/public transit/wheelchair adapted van. He/She spends about ____ hours/month in this high-risk activity.

The concept of a wheelchair transportation safety system is based on the following:

  • Using a crash-tested securement system for anchoring the wheelchair to the floor of the motor vehicle.
  • Using a crash-tested occupant restraint to hold the individual in their wheelchair and prevent secondary injury from hitting obstacles within the vehicle or being ejected from the vehicle.
  • Using a crash-tested wheelchair that includes identified securement points to correctly secure the wheelchair to the floor, an occupant pelvic safety belt, and the strength and design features to enable it to withstand 20g crash forces.

The safest place for anyone traveling in a motor vehicle is in the crash-tested vehicle seat and using the approved occupant restraint system. However:

  • Due to weakness, in-coordination, (name the functional reason) this client is unable to independently initiate and safely complete a transfer from his/her wheelchair to the crash tested automobile, paratransit or public transportation vehicle seat (identify the type of transit system).
  • The transit system (identify the transit system) used by the client refuses to take responsibility for the transfer of the client from their wheelchair to a vehicle seat. They require that the client travel using their wheelchair as a seat in a motor vehicle.
  • The transit system (identify the transit system) used by the client mandates the use of a crash tested or WC19 compliant wheelchair

Additional facts: For Use in Reports or Appeals

  • The US Department of Transportation estimates that a typical auto driver will have a near accident 1 to 2 times per month and all drivers will be in a collision of some type every 6 years on average. Studies have shown that wheelchair-seated passengers have more injuries related to vehicle swerving and emergency braking than vehicle collisions (Shaw, 2003).
  • The National Safety Council (NSA) reports there are more than 12 million motor vehicle accidents annually including more than 20 million vehicles. This results in over 5 million nonfatal accidents annually of which approximately 2 million cause disabling injuries. If the population of the US is ~300 million and ~ 2 million use wheelchairs (2000, NIDRR) this translates to ~1% of the population. This group, already more vulnerable to injury, if the percentage is held even, might be involved in ~12,000 Motor Vehicle Accidents per year.
  • The $200.00 (approximately or give the exact amount of the transit option if it is known) is small in comparison to the cost of even one emergency room visit. The transit option may prevent serious injury and potential worsening of the level of impairment with all of its related costs.
  • Avoiding the responsibility of paying for the transit option, in the event of a serious impact and related failure of the wheelchair, may open the door for legal action against the funding source for failing to meet the needs of a client that have been documented in evaluation and recommendations by a licensed health care professional.

Developed by Mary Ellen Buning and the RERC on WTS team (2005)