Wheelchair seat cushion testing, standards, codes and reimbursement
are multiple sides of the same coin…if a coin had about a
dozen different sides. Assigning appropriate codes to cushions is
necessary for adequate reimbursement. Defining codes is necessary
to understand which cushions belong within them. Testing
cushions determines the codes they should have. Determining the
standards cushions should meet, such as how many test cycles
they need to survive, helps to define what clinicians, ATPs and
consumers should expect from different cushions.
It’s a complex relationship with a long history, said Rita Stanley,
VP of government relations at Sunrise Medical.
“New seating codes were implemented in 2004,” she said.
“One of the primary goals at that time was to address the fact
that there was a single code: E0192, Low Pressure and Positioning
Equalization Pad. The SADMERC, a Medicare contractor prior to
the [current] PDAC, requested new HCPCS codes to represent
the high number of products in the E0192 and the myriad array
of technology and varying efficacies for addressing skin injuries
Stanley said stakeholders spent years on the coding proposal.
“The Medical Directors (this project spanned more than one)
worked with several experts and the RESNA product standards
board to link product testing to the new codes with the goal of
ensuring product quality and efficacy to the extent possible.
There were limitations in terms of testing, and as hard as the
RESNA board and researchers worked to establish tests to
demonstrate a product’s ability to provide skin protection,
time ran out.
“The codes were announced and implemented; the result was
that a wide array of skin protection products remained grouped
into one code, and the initial fee schedule was inadequate to
allow access to fluid technology, the technology with a history
of reliability and what clinicians depended on for people at high
risk or with a history of skin injuries. The SADMERC and CMS
promptly responded and created a distinction with the skin
protection code for ‘adjustable’ and allowed products with the
capability of adding or removing material after delivery.”
Stanley said stakeholders recognized this as “not the best
only the most expeditious one, and there was a commitment
to continue to consider a way to define the important
cushion materials and characteristics that would distinguish the
various levels of skin protection technology. In addition, the
SADMERC agreed to continue to work with researchers and
RESNA to develop tests to demonstrate the abilities of cushions
to meet any newly developed criterion.”
Then, the SADMERC lost the Medicare contract, and the
cushion provision wasn’t included in the PDAC contract.
“Changes to the initial codes created in 2004 have not
happened,” Stanley said. “As a result, the number of models that
have been coded under E2603 (skin protection seat cushion,
width less than 22″, any depth) and E2622 (adjustable skin
protection seat cushion, width less than 22″, any depth) since
these codes were implemented is approximately 1,700 and
1,400, respectively. Not all of these models are valid for billing
under these codes today, but there are still a high number of
products that are, and there is little meaningful code distinction
between these models, while the actual technology differences
varies. Moreover, the coverage requirements are
the same. This makes it difficult for inexperienced clinicians
or consumers of this technology to make educated decisions
regarding the most appropriate technology in a given situation.”
So, inexact coding and inappropriate product assignments
within cushion codes continue. “As efforts to control utilization
and cost has become a priority for payors, having HCPCS codes,
definitions and defined characteristics is more important than
ever,” Stanley said.