The Centers for Medicare & Medicaid Services (CMS) has revealed its first coding recommendations following its May decision to cover powered seat elevation on power wheelchairs for Medicare beneficiaries.
The announcement came as part of CMS’s agenda for its Nov. 30 public meeting on Healthcare Common Procedure Coding System (HCPCS) codes.
Waiting for More Info Since May
In mid May, CMS said it would start covering seat elevation on power wheelchairs for Medicare beneficiaries. But though the May decision went into effect immediately, CMS did not provide information on coding or allowables.
CMS added in May that it would cover seat elevation not just on Group 3 Complex Rehab Technology (CRT) power chairs, as the CRT industry had requested, but also on Group 2 consumer power wheelchairs.
Now, preliminary coding information announced by CMS the week of Nov. 6 provides insight into how the agency could approach the questions of coding and allowables.
The CRT industry had recommended eliminating the E2300 code (Wheelchair accessory, power seat elevation system, any type) and adding two new seat elevation codes based on wheelchair rider weight.
The industry suggested new codes for “Wheelchair accessory, power seating system, Complex Rehab seat elevation, standard weight capacity (up to and including 300 lbs.),” and “Wheelchair accessory, power seating system, Complex Rehab seat elevation, heavy duty weight capacity (301 lbs. up to and including 450 lbs.”
CMS said NCART, in submitting its recommendations, noted, “It is important to distinguish CRT seat elevation from the seat elevation incorporated into Group 2 seat elevation power wheelchairs [with HCPCS codes] K0830 and K0831.”
CMS said NCART also described seat elevation functionality on CRT power chairs: “The recommended code characteristic requirements for both of the requested new CRT power seat elevation codes are clinically relevant, supported by evidence, and include: (1) elevation of at least 10 inches, (2) capable of elevating/descending while the power wheelchair moves, (3) capable of moving on a horizontal surface while fully elevated, (4) compatible with other power seating options (i.e., tilt and/or recline).”
Defining Differences in Rider Weight
NCART also contended that seat elevation systems designed with rider weight capacities of more than 300 lbs. needed their own HCPCS code.
CMS quoted NCART’s comments as saying, “A unique HCPCS code is needed to represent patient weight capacity and accurately reflect the additional complexity associated with elevating a patient weight of 301-450 lbs. To provide the durability, strength, and stability of a CRT heavy-duty (HD) seat elevation system for use on CRT HD power wheelchairs, the HD systems require robust components to safely lift the full weight of the patient and any additional power seating systems necessary and other components. These systems must pass different test requirements due to the additional weight capacity. They must be able to maintain stability with a frequently changing center of gravity as the individual shifts to reach and to perform mobility-related activities of daily living.”
In its preliminary coding recommendations, CMS disagreed with the CRT industry’s contention that heavy-duty seat elevation systems are different in construction and therefore more costly than standard seat elevation systems.
“Our research did not show a significant price difference between power seat elevation systems based on weight class for complex rehabilitative power wheelchairs,” the meeting notes said. “Instead, the price differences based on weight class exist between the base CRT power wheelchairs themselves.”
Therefore, CMS said it does not see a need for two HCPCS codes and intends to establish only one CRT seat elevation code while adding, “We welcome comments on this finding.”
CMS Recommends Two Seat Elevation Codes
In the meeting notes, CMS said it was recommending eliminating the E2300 code and adding two new codes: “Complex rehabilitative power wheelchair accessory, power seat elevation system, any type,” and “Power wheelchair accessory, power seat elevation system, any type.”
CMS added, “The second code listed here, ‘Power wheelchair accessory, power seat elevation system, any type,’ describes only the seat elevation system and thus could be billed for use with a non-complex rehabilitative Group 2 power wheelchair base. CMS believes the establishment of this new accessory code may obviate the need for existing non-complex rehabilitative Group 2 codes that describe an integrated seat elevation system and a Group 2 power wheelchair base.”
Because of this, CMS also recommended eliminating the K0830 (Power wheelchair, Group 2 standard, seat elevator, sling/solid seat/back, patient weight capacity up to and including 300 lbs.) and K0831 (Power wheelchair, Group 2 standard, seat elevator, captain’s chair, patient weight capacity up to and including 300 lbs.) codes.
CMS Announces Preliminary Payment Recommendations
CMS said the CRT industry had suggested that funding for seat elevation on CRT power chairs be compared to allowables for power tilt systems on CRT power chairs. But the agency disagreed.
“We do not believe this to be an appropriate comparison,” CMS said in its meeting notes. “Different mechanical components are used to effect seat elevation from seat tilt (for example, seat elevation may use a telescoping seat post or scissor-lift component, while tilt would use a hinged mechanism with a geared connection to the motor), and while seat tilt must accommodate an expected shift in the center of gravity from front-to-back, seat elevation only impacts the center of gravity in the vertical axis. For these reasons, we find that seat elevation is not comparable to any item with an existing fee schedule amount, and so the gap-fill approach is the most appropriate method for making a payment determination.”
To preliminarily establish allowables, CMS said it compiled a list of 20 CRT power chairs currently able to accommodate seat elevation and examined the pricing of those systems.
“The average price across the seat elevation systems we found would be classified in this code was $3,450.60,” CMS said. “The annual deflation factors are specified in program instructions, and the deflated amounts are then increased by the update factors specified in section 1834(a)(14) of the Act for DME. Based on these adjustments, the purchase price would be approximately $2,261.89.
“Under the capped rental rules for complex rehabilitative power wheelchairs, the rental price would be approximately $339.28 for months 1-3, and $135.71 for months 4-13 for a total of $2,374.94 for 13 months of continuous use.”
CMS said it had no determination for allowables for the second proposed code, explaining, “As an extensive review of evidence to determine the coverage criteria for power seat elevation equipment for non-complex rehabilitative power wheelchairs is not complete, we are unable to determine the appropriate universe of seat elevation equipment that may be covered as a Medicare benefit under this code and, for this reason, we are unable to develop an appropriate payment amount at this time.”
The agency noted the relatively wide range of seat elevation pricing — “from around $600 to over $2000” — for consumer power chairs.
CRT Stakeholders’ Next Moves
In response to the CMS announcement, NCART said in a Nov. 8 bulletin, “The NCART Coding Workgroup has reconvened following the announcement and is preparing testimony for the CMS hearing, which is scheduled for November 30, 2023. Comments will address questions and concerns related to both coding and pricing. NCART is also encouraging manufacturers, providers, clinicians, and other stakeholders to submit written comments.
“The public meeting provides an opportunity for stakeholders to offer further comments related to modifications to the HCPCS code set. CMS’ final coding, benefit category, and payment decisions are expected to be published on CMS’ HCPCS Web site in February 2024 and effective April 1, 2024.”
The CMS HCPCS code meeting will take place via Zoom, Thurs., Nov. 30, from 9 a.m. to 5 p.m. Eastern time. CMS is currently asking speakers (primary or five-minute presenters) to register by Nov. 14. After speaker registration closes, other attendees will be invited to register.