A new Medicare Learning Network (MLN) Matters article from the Centers for Medicare & Medicaid Services (CMS) states what seating & mobility clinicians and providers have known all along: Ultralightweight manual wheelchairs, HCPCS code K0005, are complex rehab technology products.
MLN Matters article SE1233, issued Sept. 10, is called “Clarification of the Quality Standards and Accreditation Requirements for Ultra Lightweight Manual Wheelchairs.”
It alerts providers that for ultralight claims with dates of service on or after March 1, 2013, suppliers will have to be in compliance with DMEPOS Quality Standards and accreditation requirements.
K0005s Defined as Rehab Products
Ultralightweight manual chairs have long been known by clinicians and rehab providers to be complex, highly customized pieces of technology.
In the MLN Matters article, CMS officially agreed.
“Ultralightweight manual wheelchairs, Healthcare Common Procedure Coding System code K0005, are highly configurable manual wheelchairs for highly active full-time users,” the article states. “The ultralightweight manual wheelchairs require individualized fitting and optimal adjustments for multiple features that include axle configuration, wheel camber, and seat and back angles, in addition to ongoing critical support.
“These services are furnished by a Rehabilitative Technology Supplier (RTS). Therefore, these items are considered complex rehabilitative wheelchairs subject to the requirements of DMEPOS Quality Standards, Appendix B, Manual Wheelchairs, Power Mobility Devices (PMDs), and Complex Rehabilitative Wheelchairs and Assistive Technology, Section III, Complex Rehabilitative Wheelchairs and Assistive Technology.”
By defining K0005 chairs as complex rehab products, CMS notes that providers “must employ at least one Assistive Technology Professional (ATP) effective for services on or after March 1, 2013, in order to bill Medicare for the K0005 wheelchair.”
Complying with Complex Rehab Policies
CMS has implied in the past – albeit under strong industry lobbying and prompting – that it considered K0005 chairs to be complex rehab items. For instance, CMS removed ultralights from the list of products to be included in Medicare competitive bidding’s round 2. Complex rehab is carved out of that program.
The MLN Matters article, however, clarifies the situation, while also reminding providers of the policies that apply to such products.
Starting in March, suppliers providing K0005 chairs must employ an ATP or certified complex rehabilitative technology supplier (CRTS), defined as a registrant with NRRTS who is in good standing, has passed RESNA’s ATP exam, and maintains the ATP credential.
The supplier must also have at least one trained technician at each location to service the product. Technician training, by CMS definition, must include at least 10 hours of annual continuing education training that focuses on rehab technology.
The supplier must also “coordinate services with the prescribing physician to conduct face-to-face evaluations of the beneficiary in an appropriate setting and include input from other members of the health care team,” such as physical or occupational therapists. Suppliers providing K0005s must maintain repair areas within their own facilities or “easily accessible from another location of the supplier,” and must provide “private, clean and safe rooms appropriate for fittings and evaluations” if beneficiaries are assessed on site.
