The Centers for Medicare & Medicaid Services (CMS) has stated that existing Medicare reimbursement for dynamic wheelchair backrests is appropriate based on its analysis.
That decision was part of the CMS Healthcare Common Procedure Coding System (HCPCS) Level II Final Coding, Benefit Category and Payment Determinations, Second Biannual 2023 HCPCS Coding Cycle, released at the end of February. The report noted the final determination for Dynamic Seating Component Application #19.120 was for informational purposes only.
Comparison to E1015
The CMS report said the request was for Medicare payment determination “for existing HCPCS Level II code E2398, ‘Wheelchair accessory, dynamic positioning hardware for back.’”
In summarizing the applicant’s submission for consideration, CMS described a dynamic back as consisting of “dynamic components, joints, linkages and elastomers, and is designed to be attached to a wheelchair frame. The system is designed to accommodate the wheelchair user’s flexion and extension with minimal displacement at the pelvis during movement, and the variable spring returns the individual back to their initial posture.
“Static wheelchair frame components do not allow for an individual’s abnormal and uncontrolled movement within the system and cannot withstand the high level of repeated force these individuals can exert. As the person extends, flexes, stretches, and shifts his or her weight due to high tone, uncontrolled movement, or [to] relieve discomfort or pressure, the dynamic component responds to the forces that movement produces.”
The coding cycle report noted that CMS established HCPCS code E2398 — “Wheelchair accessory, dynamic positioning hardware for back” — in January 2020, and determined in October 2022 that dynamic wheelchair backs do meet CMS’s Medicare definition of durable medical equipment.
In May 2022, CMS published a preliminary Medicare payment determination that said the agency would create fee schedule amounts based on “comparable items described by HCPCS Level II code E1015,” defined as “Shock absorber for manual wheelchair, each.”
Industry: Dynamic backs are different systems
CMS noted that at a June 2022 public meeting, NCART and three manufacturers of dynamic backs said dynamic back hardware is in fact not comparable to shock absorbers on manual wheelchairs.
Those comments, CMS said, contended that dynamic back hardware “is not comparable to the E1015, indicating that the dynamic back hardware is not comparable in function, strength, or durability and handles a vastly different set of forces than shock-absorbing devices described by HCPCS Level II code E1015.”
CMS added that an occupational therapist who is a consultant for Seating Dynamics, one of the three manufacturers participating in that June 2022 public meeting, “provided written comments that items described by code E1015 are intended to provide suspension, which can reduce vibration and jarring from uneven terrain, but is different from dynamic seating, which is activated by client forces and then returns a client to a preferred starting position.”
In further written comments, CMS said NCART contended that dynamic back hardware “is potentially comparable to E2295,” defined as “Manual wheelchair accessory for pediatric size wheelchair, dynamic seating frame, allows utilization of the code from which to establish pricing.”
NCART therefore asked that gap-fill pricing be used to determine payment for E2398, “but that the establishment of pricing through this methodology be deferred until there is sufficient payment history with which to establish a price.”
CMS rebuttal: Comparison to E1015 is accurate
In the end, CMS decided that its earlier comparison of dynamic backs to E1015 shock absorbers was accurate.
“While we appreciate NCART’s analysis and suggestion that the dynamic back hardware may be comparable to HCPCS Level II code E2295, we do not agree,” the coding cycle report said. “HCPCS Level II code E2295 is used to describe the wheelchair back and shock absorbing or dynamic seating hardware; it is not used to only describe the dynamic back hardware feature. … In addition, we believe that NCART did not demonstrate significant evidence or studies to suggest that [a] dynamic back differs from shock absorption and is not comparable to E1015.”
Functionally, CMS said dynamic backs and shock absorbers provide the actions: “Regardless of the source of the force (from the ground/terrain below the wheelchair frame or from the patient sitting above the wheelchair base), when that force is applied, both the dynamic positioning back hardware and devices under E1015 reduce the shear forces and allow movement with return to a neutral or starting position.”
The coding cycle report included 2023 fee schedule amounts for E1015. Those amounts are $152.55 to $183.02 for Complex Rehab Technology wheelchairs; $149.79 to $166.14 for standard wheelchairs in rural and non-contiguous areas; and $131.95 to $145.04 for standard wheelchairs furnished in other areas.
The information about dynamic backs was included in the same coding cycle document that contained final coding, benefit category, and payment information for seat elevation on power wheelchairs.
