Industry Takes First Look at CMS' New Power Mobility Codes
Power wheelchair and scooter manufacturers, dealers and the beneficiaries who use those vehicles are in a holding pattern of sorts following the release of power mobility device (PMD) codes late on June 2 by the Centers for Medicare & Medicaid Services (CMS).
CMS released 64 codes in six different groups according to vehicle size, weight capacity, seating, power positioning options and performance characteristics such as top speed, operational range and dynamic stability incline. The new list includes 61 defined codes and three miscellaneous codes, all starting with an "XXX" prefix. Those codes will be replaced by K codes for billing purposes prior to Oct. 1, 2006, when CMS has said the new codes will become effective.
What were still outstanding, as of eMobility's June 6 press time: fee schedules for the new codes; lists of codes for specific wheelchair and scooter brands and models, along with new testing guidelines; and the all-important local coverage determination (LCD) that will spell out which mobility devices beneficiaries qualify for in the first place.
In releasing the codes, posted to the Statistical Analysis Durable Medical Equipment Regional Carrier (SADMERC) Web site, CMS said a "companion document with full narrative and performance descriptions will be published soon," to be followed by a product classification list to show which codes applied to specific wheelchairs and scooters. Policy and pricing updates, CMS added, would be announced "later this summer."
All power chairs and scooters seeking codes will have to be retested under new procedures suggested by the Technical Expert Panel (TEP) commissioned by CMS to help with the coding project. The testing standards and deadlines for completing the new tests have yet to be announced.
To download a pdf of the new power mobility device code list, go to http://www.palmettogba.com/palmetto/other.nsf/Home/Other+Medicare+Partners+SADMERC+Home?OpenDocument.
Initial code list responses from a sampling of power mobility manufacturers had an understandable wait-and-see undertone, as they wait for CMS to pass on additional all-important details.
"The codes provide a general framework," said Invacare's Cara Bachenheimer. "We need three additional pieces of information to really understand the bottom line, which is really beneficiary access to the appropriate productà Until we have a definition of what the specific criteria will be for each of these levels of product, we won't know whether beneficiaries will be able to qualify for the appropriate product set."
Seth Johnson of Pride Mobility Products/Quantum Rehab said the PMD code list "raised almost more questions than they answered. We still are looking for the companion document that the SADMERC references will be published soon; that will provide the full narrative and performance descriptions. I've heard we could see that as early as this week, and we really need that companion document to answer a lot of our initial questions and fully assess the impact of these codes."
Sunrise Medical's Rita Hostak agreed that with many of the pieces still missing "it's hard to know how all of it's going to impact the industry and impact access to various levels of technology until you put all the pieces together." That being said, Hostak also lauds "CMS, the SADMERC and the people who served on the TEP. When you think about it, it's been 10 years that the industry's tried to really convince CMS that the existing K0010, K0011, K0012, K0014 codes were not adequate and not working. And they really took all the information that we put out there and took I think a fresh look at it. You can tell that the same technology's really represented in this code set that was represented in the two previous proposals that CMS put out. But I think they took it and applied a different paradigm when they said rather than looking at individual codes or rather than looking at a lot of different categories, instead let's look at groups and align those groups based on various clinical applications and patient populations. And then we'll go into each one of those groups and kind of slice and dice it based on different features and characteristics of the product.
"That's about as far as I can get on just the face value of what we got on Friday. The real outcome ù how it gets applied in the real world ù is going to depend on the LCD, fee schedules and all the stuff that we've yet to see."
Permobil's Darren Jernigan was optimistic upon seeing the code list: "I think it's going to be a great thing," he said. "There's no more custom chairs. You won't need a miscellaneous code because you have (more specific codes)." Jernigan said he felt "encouraged" by the code list, but also wondered about corresponding allowables. "That's the most important part," he says. "What's the point if you can't get an allowable?"
When the allowables are released, "That low-end category, where all the cheap product is ù I don't think they're going to survive," Jernigan said. "I think you'll see those codes there, and no one in business to provide them. With competitive bidding, allowables are going to be so low for those." Gone are the days, Jernigan pointed out, when less expensive and more complex chairs were billed using the same K0011 code. "I don't know that anyone's going to be able to provide (very basic power chairs) without being in the higher-end chairs, too."
"We have the basic framework of what it is (CMS) is looking to roll out," Johnson agreed. "But we just don't have a lot of the specific definitions and descriptions for these code categories and how they would break them up.
"You also have the fee schedules that are going to be a very important element to this puzzle. And there's been a lot of discussion with CMS, and CMS readily admits, that the gap-filling methodology that is traditionally used to price new codes is flawedà I just think there needs significant time and reflection of the new fee schedules once they're released in order to ensure that prior to going forward, we have an appropriate plan in place to assure appropriate access to beneficiaries."
Bachenheimer also wondered how the still-outstanding LCD will play out. "The DMERCs and CMS may take the position that the medical policy that was issued in draft form last September 14 was a draft, so they may just go ahead and issue a final policy. If they make that decision, they will not have to release that final medical policy until Sept. 1; there's a 30-day notice requirement for new medical policy at the DMERC level. If they take the better route and issue a draft, we would need to see that pretty soon, because they would have to take comments and incorporate those and issue a final by Sept. 1. This is assuming that they stick with the Oct. 1 start date."
For now, power mobility manufacturers and suppliers alike are mulling over what CMS has released so far, and waiting for what's to come. "Dr. (Doran) Edwards (SADMERC medical director) told us to keep checking the SADMERC Web site later this week," Bachenheimer said, "because they're expecting to issue more information."