If our same-day coverage of the March 25 DME MAC-hosted local coverage determinations (LCDs) meeting for power mobility devices and seat elevation was TL;DR — here are the highlights, as well as our take on their potential impact.
— It’s all about preserving individual consideration and access. The DME MACs — Noridian Healthcare Solutions (Jurisdictions A and D) and CGS Administrators (Jurisdictions B and C) — have proposed LCDs saying that Group 2 power chairs with seat elevation — HCPCS codes K0830 and K0831 — are not reasonable and medically necessary; and that seat elevation added to power wheelchairs in the “non complex” category isn’t, either.
Peter Thomas, co-coordinator of the ITEM Coalition and Powers managing partner at health care law firm Powers Pyles Sutter & Verville, was the first industry speaker of the meeting. Thomas said the LCDs “not only conflict with the letter, but certainly with the spirit of the national coverage determination [NCD] and the national coverage analysis [NCA] that was published in May of 2023” by the Centers for Medicare & Medicaid Services (CMS).
His objection to the LCDs comes down to this: “Diagnosis alone should never dictate coverage.” And he listed conditions — limb loss, pressure injuries, chronic obstructive pulmonary disease (COPD), congestive heart disease, myositis, and rheumatoid arthritis, among others — that could require wheelchair use in the home.
Julie Piriano, PT, ATP/SMS, senior director of payer relations and regulatory affairs for the National Coalition for Assistive & Rehab Technology (NCART), spoke next. She agreed that the LCDs should align with the NCD and NCA, and added, “We further request that the DME MACs allow for individualized decision-making based on the clinical evaluation and documentation of each beneficiary’s unique medical needs and functional limitations that would be reviewed on a case-by-case basis.”
Neither Piriano nor Thomas argued for universal approval of seat elevation for every non-complex Group 2 power wheelchair user. But they argued against the opposite, as well: No automatic denials of seat elevation for Group 2 non-complex power chair users.
Give clinicians the ability to assess each client’s needs, Thomas and Piriano urged. Maintain access to seat elevation when it’s clinically justified and appropriately documented.
— Seat elevation provides the same benefits, regardless of power base. Transfers, reach-related tasks, reducing fall risk: Seat elevation supports all of those goals, regardless of what its power chair’s HCPCS code is.
Piriano and Thomas both used personal examples of how seat elevation makes mobility-related activities of daily living (MRADLs) safer and more efficient. Piriano said her dad could heave laundry into the washing machine while sitting in his manual chair, but power seat elevation enabled him to also turn the washer on, then remove the clean laundry afterward.
Thomas, a bilateral amputee since age 10, said five decades in a wheelchair have worn out his shoulders, and that seat elevation “is extremely helpful to enable me to stand much more easily, to be able to reach, to be able to do all kinds of things that this policy would allow.”
— NCART recommended access to power seat elevation used with Group 2 non-complex power chairs — coded K0822 through K0829 — with aligned coverage criteria. Without that guarantee, Piriano said, NCART “cannot support any proposal to eliminate two Group 2 power wheelchair base codes, K0830 and K0831.”
The recommendation would preserve access to seat elevation based on an individualized assessment of medical need.
And NCART supports “adding seat elevation systems to the list of DMEPOS PMD [durable medical equipment, prosthetics, orthotics and supplies power mobility device] accessories eligible for voluntary prior authorization when the prior authorization request includes a corresponding power mobility device.”
Prior authorization would ensure there is no unwarranted spike for seat elevation for non-complex Group 2 power chairs … although Piriano added that NCART had reviewed CMS data for HCPCS codes K0822, K0823, K0830 and K0831, which showed “less than 10% of the Group 2 non-complex power wheelchairs covered through traditional Medicare Part B included a power seat elevation system in 2024 and 2025 combined.”
So, no usage spike is expected, but prior authorization would be an extra layer of proactive protection.
— The public comment period closes April 4. Note that comments on the two LCDs need to be separately submitted; you can’t combine them and send one email. Send your comments this way: [email protected] (power mobility devices LCD) with the subject line “Public Comment for Proposed LCD — PMD (DL33789) and/or [email protected] (wheelchair options/accessories) with the subject line “Public Comment for Proposed LCD — WCOA (DL33792).
Thomas and Piriano, with time limits of 15 minutes each, did an excellent job of explaining clinical, documentation, policy and consumer perspectives to the DME MACs. Now, via the comment period, it’s our turn to speak up.
