NCART: CMS “Re-Interpretation” of Wheelchair Frame Policy Threatens Access

A Centers for Medicare & Medicaid Services (CMS) “re-interpretation” concerning titanium wheelchair frames and upgraded patient weight capacities threatens Medicare beneficiary access to affected manual wheelchairs, NCART said in a recent bulletin to stakeholders.

In a Jan. 26 notice, NCART Executive Director Don Clayback noted that in December, the DME Medicare Administrative Contractors (DME MACs) “issued a joint publication indicating that titanium wheelchair frames and patient weight capacity upgrades were not separately billable to Medicare.”

A Dec. 15 joint publication from the DME MACs said the contractors had reviewed usage of the K0108 accessory code and determined that the use of titanium and/or a heavy-duty package designed to support higher beneficiary weights were already included in manual wheelchair fee schedules, and therefore are not separately billable.

“The Medicare fee schedule amount for these codes was established with the original code and included the cost of titanium-containing manual wheelchairs,” the joint publication said. “Suppliers billing for manual wheelchair bases must not include HCPCS code K0108 in addition to the base wheelchair code when a wheelchair is constructed of titanium or for a ‘heavy duty package’ reflecting titanium construction materials.”

Clayback contends that the announcement is another case in which CMS alters course in a way that hurts Medicare beneficiaries.

“This is the most recent example of policy changes and re-interpretations over the past few years implemented by CMS and its contractors that eliminate access,” Clayback said in his letter to the industry. “This policy announcement prevents Medicare beneficiaries with disabilities from obtaining complex rehab technology (CRT), even if they are willing to pay for upgrades themselves.”

In an NCART issue paper being distributed to industry advocates and policy decision makers, Clayback argues that the technology landscape was very different when the manual wheelchair base reimbursement amount was established in 1993. “These capabilities and materials were not widely available in 1993, and for years suppliers have used a ‘not otherwise classified’ code to bill for these additional costs,” the issue paper says. “And many payors, including Medicare, approved them. For Medicare, if suppliers provided and billed for such items, beneficiaries could choose to pay the difference themselves in cases where coverage was denied, but not anymore.”

To ensure continued beneficiary access to the technological benefits offered by more recent functional improvements, the issue paper says CMS should rescind the new policy and issue a clarification to confirm that providers can continue to use K0108 to bill for titanium K0005 (ultralightweight) manual wheelchairs. The issue paper also calls for providers to be able to use K0108 to bill for heavy-duty upgrades to the K0004 (high-strength, lightweight), K0005 and E1161 (adult manual tilt in space) codes.

Download a copy of the issue paper HERE.

“We have also reached out to CMS with our concerns and are pursuing other channels in the Congressional and advocacy arenas,” Clayback said. “We will keep you updated on our progress and next steps that may be required.”

About the Author

Laurie Watanabe is the editor of Mobility Management. She can be reached at

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