The Centers for Medicare & Medicaid Services (CMS) has issued its final coding, benefit category, and payment determinations for seat elevation on power wheelchairs.
The determinations were included as part of CMS’s Second Biannual 2023 HCPCS Coding Cycle. CMS said new coding actions would be effective starting April 1, 2024, unless otherwise noted.
CRT industry requested standard, bariatric codes
CMS initially provided only one code for seat elevation on Complex Rehab Technology (CRT) power wheelchairs and asked for comments. The CRT industry requested a second code, for heavy-duty weight capacities from 301 through 450 lbs. In that scenario, the first code would function as a standard weight code, for weight capacities through 300 lbs.
At a Nov. 30, 2023 coding meeting, CRT seating experts advocated for that separate heavy-duty code. “Reconsider the need for a separate HCPCS Level II code for heavy-duty CRT PSE [power seat elevation], and consider the health care disparity and access to care concerns,” NCART urged in its position statement.
As one of the presenters speaking at the coding meeting on behalf of the industry, Brad Peterson, VP of U.S. Sales for Amylior, also asked CMS for a heavy-duty code, saying that without such a code, access to seat elevation would be compromised for heavier power chair users.
Peterson explained that manufacturing costs for heavy-duty power chairs are higher than the manufacturing costs for standard power chairs, and he added that engineering a heavy-duty power chair is complicated because many bariatric wheelchair riders carry their body weight asymmetrically — a fact that heavy-duty power chairs and seating must be able to accommodate.
Peter Thomas with the ITEM Coalition and the Powers Pyles Sutter & Verville law firm, agreed with Peterson, saying in the coding meeting that foregoing a separate heavy-duty code could be dangerous. “People will potentially be at risk,” Thomas noted.
CMS coding decision excludes heavy-duty code
Despite industry lobbying, CMS’s final coding decision added just one CRT seat elevation code. Effective April 1, CMS will establish E2298, defined as “Complex rehabilitative power wheelchair accessory, power seat elevation system, any type.”
On March 31, CMS will officially discontinue the previous E2300 code that was “Wheelchair accessory, power seat elevation system any type.”
In explaining why it did not create a heavy-duty seat elevation code, CMS referred to CRT representatives who spoke during the November coding meeting.
In one example, CMS said, “The speaker asked CMS to reconsider the need for a separate code for HD CRT PSE [heavy-duty Complex Rehab Technology power seat elevation], stating there could be access issues involved for Medicare beneficiaries above a certain weight due to the payment being too low to cover the additional costs of construction for HD PSE systems.”
Ultimately, however, CMS stayed with the policy it originally proposed.
“We recognize that seat elevation equipment for a bariatric patient population necessarily requires special attention to ensure that components are fabricated with the necessary specifications and that the seat elevation equipment meets stability testing requirements,” the agency said. “However, the public comments confirmed that regardless of any differences in fabrication cost, there is no significant difference in the commercial pricing for seat elevation equipment for heavy-duty power wheelchairs and seat elevation equipment for standard power wheelchairs.”
Group 2 coding decisions postponed
CMS did side with the industry experts who recommended the agency pause its original proposal to delete 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.) HCPCS codes.
Referring to an industry representative at the November coding meeting, the CMS decision said, “The speaker also asked CMS to defer the creation of a new HCPCS Level II code for standard seat elevation and the deletion of codes K0830 and K0831 to a subsequent cycle until such time as NCART has been able to thoroughly consider such changes. The suggested code language ‘Complex rehabilitative power wheelchair accessory, power seat elevation system, any type,’ would make it so that the wheelchair user would have to install power tilt or recline, both described as ‘power seating systems’ in the current code set, to obtain additional components such as E1010 and E1012. Currently, the code language for those components, power leg elevation system and platform respectively, read as, ‘Wheelchair accessory, addition to power seating system.’
“CMS received many comments from manufacturers of CRT products, groups representing suppliers, consumers, providers, advocates and stakeholders, all in support of the primary speaker’s comments and recommendations,” the decision said, referring to speaker Julie Piriano, PT, ATP/SMS, VP, Clinical Education, Rehab Industry Affairs and Compliance Officer, Quantum Rehab.
“In the interim,” the decision added, “HCPCS Level II codes K0830 and K0831 will continue to be used for non-complex rehabilitative power wheelchairs with seat elevation equipment. HCPCS Level II code K0108 (Wheelchair component or accessory, not otherwise specified) can be used for claims for power seat elevation equipment added onto a non-complex rehabilitative power wheelchair owned by the beneficiary.”
Regarding reimbursement rates, the CMS decision added, “With respect to code K0830 and K0831, and claims for power seat elevation equipment added onto a non-complex rehabilitative power wheelchair owned by the beneficiary that are billed using code K0108, local fee schedule amounts would be calculated by the DME MACs for use in paying claims for any covered items.”
Seat elevation as a system unto itself
CMS disagreed with the CRT industry on a critical issue: the fundamental and functional definition of seat elevation systems.
In the November meeting, Piriano urged CMS to “adopt the code description proposed in the NCART code application and recognize CRT PSE as a stand-alone system, the same as power tilt and/or power recline, and not merely as an add-on component.”
“We note that the applicant suggested that power seat elevation for a complex rehabilitative power wheelchair should be considered comparable to power seat tilt for a complex rehabilitative power wheelchair,” CMS said in the coding decision. “We do not believe this to be an appropriate comparison.”
CMS based its decision on its belief that “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.”
That definition impacts the reasoning behind CMS’s funding decisions. “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 decision,” the final decision said.
Fee schedule changes will start in April
In a Feb. 29 bulletin to the industry, NCART said the fee schedule amount for the new E2298 code is $2,000.34, and that the fee schedule would be effective April 1.
The American Association for Homecare (AAHomecare) said in a March 1 bulletin, “Under the capped rental rules for complex rehabilitative power wheelchairs, the rental price would be approximately $200 for months 1 through 3, and $150 for months 4 through 13 for a total of $2,100 for 13 months of continuous use.”
“To ensure an appropriate universe of commercial pricing for seat elevation systems that would be classified in this code, we compiled a list of all complex rehabilitative wheelchairs with power seat elevation options available on the Product Classification List for the relevant base wheelchair codes,” the CMS final decision said. “We verified the comprehensive nature of this list by comparing against manufacturer websites and websites of wheelchair suppliers. We further ensured that this list included all of the seat elevation options specifically mentioned by the applicants.
“In total, we identified seat elevation equipment for 20 power wheelchair models. We then searched for the best pricing available online for each of these seat elevation options. We excluded any supplier that did not advertise a full manufacturer’s [warranty] or being an ‘authorized’ supplier. We further excluded discounts that appeared to represent a time-limited or unique offer (e.g., ‘10% off your first order’). Finally, we excluded prices for suppliers that did not offer standard customizations, for example, suppliers offering refurbished units or with limited build options (e.g., only pre-build models that could not be further customized to reflect beneficiary needs).”
The CMS list included CRT power chairs from manufacturers Amylior, Invacare Corp., Merits Health Products, Permobil, Quantum Rehab, Rovi Mobility, and Sunrise Medical.
The CRT industry reacts
“AAHomecare’s Complex Rehab & Mobility Council will share additional analysis as applicable,” the association said in response to the final coding decision.”
And NCART said it “is conducting further analysis of the decision and will have a more detailed report to share [the week of March 4].”
The CRT industry continues to wait for CMS’s response to a request for Medicare funding consideration for power standing on complex power chairs, a request first filed in September 2020. The power standing request was filed simultaneously with the request for Medicare funding for seat elevation on complex power chairs, a process that finally got underway in August 2022.