Aiming for Oct. 1: Countdown to New Power Codes Is Underway
The start of summer is still officially two weeks away, but the HME mobility/rehab industry is already looking at the calendar and thinking about fall.
That's because according to word from the Centers for Medicare & Medicaid Services (CMS) last Friday, the new power mobility device codes ù 64 total ù will go into effect on Oct. 1, 2006.
Given that the code list came out late June 2 and that the industry is still awaiting a product classification list, a local coverage determination (LCD) and a fee schedule, is Oct. 1 a realistic implementation date?
"I think it is a very aggressive timeframe to talk about implementation Oct. 1," says Pride Mobility Products' Seth Johnson. "There's been a lot of effort both on the part of CMS and the industry working together on the development of new codes. We all recognize there's a need for new codes, but we saw last year when 49 codes were released that there was significant time for suppliers and the DMERCs and the SADMERC to adjust to the new codes. We had seven months to test products and submit testing information to the SADMERC prior to the codes going into effect.
"Then those codes were pulled back, and they released the 63 codes, and those were pulled back, and we saw the TEP come together to work on new codes that are reflected in this new document. But in order for CMS to appropriately implement these new codes, they also have to publish an LCD and typically, the process once an LCD is published there's a 45-day comment period and a 45-day implementation period. So you're looking at three months right there."
Says Sunrise Medical's Rita Hostak, who is also president of the National Coalition for Assistive & Rehab Technology (NCART): "It's one of those things that if all the planets align perfectly, then it can happen. There's just a lot that needs to be done."
Hostak wonders, for instance, about coverage criteria: "I guess the piece I'm missing is I don't know how long it'll be before the DMERCs will put out an LCD. And that to me is a big piece of understanding this. From a rehab provider's perspective, one of the issues is going to be that if all this stuff's not released really soon, there's going to be a lot of clients that are going to be assessed for appropriate technology, and determinations on what's needed for the clients are going to be made. And the supplier really won't have any idea of how much he's going to be paid for (the equipment), or really whether the patient even meets the coverage guidelines (until the LCD is unveiled)."
Hostak adds that CMS isn't the only entity that will have to work hard to be ready by Oct. 1. "Many suppliers are still confused about the NCD (national coverage determination) and the face-to-face requirements and documentation requirements. They're going to have to continue to absorb all that information, and now they've got to (transition from) 10-plus years of utilizing essentially one K code ù even though there were four (codes), primarily products were billed with the K0011 ù and get their billing staff, referral sources, RTS's and everybody knowledgeable not just about the code set, but the coverage for it and what products fit where. You've got a fair number of codes that suppliers are going to have to get comfortable with."
Darren Jernigan, who as government affairs director of Permobil spends much of his time working with Medicaid programs, said a number of people involved with those programs are feeling anxious because of the short time between receiving the allowables information and the new codes going into effect on Oct. 1. "Some Medicaids just take 20 percent off Medicare allowables," Jernigan said. "That's their funding, and they're not going to know what the allowables are until September. Then they're going to have to implement in October."
"I don't really understand why (CMS thinks) they need to meet an Oct. 1 deadline," Johnson says. "They haven't really spelled out what the rationale is for rushing to an Oct. 1 deadline. There's just a process that needs to play itself out, that generally does play itself out from an LCD perspective and also a fee schedule perspective. And I would just hate to see the process rushed just to meet an arbitrary Oct. 1 implementation date."
After years of hearing about new power mobility codes, the industry is ready, Hostak believes, to transition to a new coding system ù it's just a matter of timing. "It's still a lot that has to happen," she says.