Let's Try This Again... The New PMD Codes
The Centers for Medicare & Medicaid Services (CMS) has announced that it has completed the new power mobility device (PMD) codes. I can't help but think, "Here we go again."
Of course, we have just been given a small peek into the final product. This may not be necessarily bad, since the best way to learn is step by step. Our best bet is to just take a deep breath and start learning.
It is true, we do have 64 new codes, including three for power-operated vehicles (POVs/scooters), two for pediatrics and three miscellaneous. That leaves 53 codes for power wheelchairs. While this may sound excessive, keep in mind that these codes must cover all power wheelchairs that are available. The chair codes may not necessarily be covered by Medicare, but the codes will be used by all other funding sources as well.
In creating these codes, CMS worked with a Technical Expert Panel (TEP). As their document states, the panel consisted "of representatives from the technical, scientific, manufacturing, supplier, testing and clinical aspects of the power mobility industry."
The key to all of this, and where confusion may exist, is that what has been developed thus far is an "interim" step. As was presented last year, all products will have to be tested to specific parameters. Those results will then be used in the code verification process. During this "interim" step, the same testing parameters will be used that were presented more than a year ago. The good news is that most manufacturers have already completed testing and submitted an application. In that case, the Statistical Analysis Durable Medical Equipment Regional Carrier (SADMERC) just needs to review the application.
The bad news is that manufacturers will have to test again in the near future, as CMS has announced (at press time) a revised set of test parameters to be published soon. There are new test parameters because CMS wants to be able to incorporate future technological advances. When the new parameters are announced, manufacturers will be given a specific timeframe in which they need to complete the new testing. The products will then be code verified again based on the new requirements. This is the reason for the "interim" code designation. To top it off, once the retesting is completed and the products are recoded, the allowables are also likely to change.
The 64 codes have been divided into six groups for power wheelchairs and two groups for POVs. As the CMS document states, the groups are "divided by performance," based on the testing parameters. The groups are also sub-divided by patient weight capacity and/or powered seating system capabilities.
Patient weight capacities are defined as standard, heavy duty, very heavy duty, and extra heavy duty. Remember, this represents patient weight capacity only, not the durability or performance of the PMD. Be sure to note that for Standard, the definition differs for power wheelchairs vs. POVs:
- Standard = PWC: 126 to 300 lbs.; POV: up to 300 lbs.
- Heavy Duty (PMD) = 301 to 450 lbs.
- Very Heavy Duty (PMD) = 451 to 600 lbs.
- Extra Heavy Duty (PWC) = 601 lbs. or more (nothing in this weight capacity for POVs)
The other differentials used within each power wheelchair code include the type of seat (sling or solid), vs. a captain's chair; portability; seat elevators; and single power options vs. multiple power options.
People have asked what I think about the change. I think it could be good, depending on the policy, the allowables and how it is actually handled. In my opinion, the big difference is that it separates what is known as "consumer" power from "complex" or "high-end rehab" power. Businesses will be affected in different ways, depending on their areas of focus. The key will be to know your business, understand it and properly implement the changes within your own company and with your referrals.
These new codes along with the new policy will not only affect external customers, but will also change the way you do business internally. This includes computer systems, which will require updating for codes and allowables, documentation requirements, and training of new policy requirements.
Finally, keep in mind that this is just the initial announcement. You can download this information by going to www.palmettogba.com, then selecting "SADMERC." At the time of this writing, the codes were set up as "XXX" plus a number. We may have more information by the time you read this; if so, the numbers will have been introduced as the new "K" codes.
We also need to wait for the policy and the allowables. We do know that there will probably be a "basic equipment package" as part of the base wheelchair as stated in the original draft medical policy last year and will not be going away.
Remember, this will go into effect for any PMDs delivered on or after Oct. 1, 2006. We will give you updates as they become available. The Orion Group will also present seminars on this topic across the country in October, so watch for presentations in your area.
As always, Orion is here to help with billing or Medicare questions. Contact firstname.lastname@example.org, or (303) 623-4411.
This article originally appeared in the July 2006 issue of Mobility Management.