Page 14 - Mobility Management, March 2017
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NCART: CMS “Re-Interpretation” of Policy Threatens MWC Access
A Centers for Medicare & Medicaid Services (CMS) “re-interpretation” concerning titanium wheelchair frames and upgraded patient weight capacities threatens Medicare beneficiary access to affected manual wheelchairs, NCART said in a recent bulletin to stakeholders.
In a Jan. 26 notice, NCART Executive Director Don Clayback noted that in December, the DME Medicare Administrative Contractors (DME MACs) “issued a joint publication indicating that titanium wheelchair frames and patient weight capacity upgrades were not sepa- rately billable to Medicare.”
This contradicts a separate billing policy that has been used by complex rehab technology providers for years to process titanium and heavy-duty frame upgrades.
“Suppliers ... Must Not Include HCPCS
Code K0108”
A Dec. 15 joint publication from the Medicare DME MACs said the contractors had reviewed usage of the K0108 accessory code and determined that titanium in manual wheelchair frames and/or a heavy-duty package to accommodate higher beneficiary weights were already included in the manual wheelchair fee schedules, and therefore are not separately billable items.
“The Medicare fee schedule amount for these codes was established with the original code and included the cost of titanium-containing manual wheelchairs,”
“This announcement prevents beneficiaries from obtaining CRT, even if they are willing to pay for upgrades themselves”
the joint publication said. “Suppliers billing for manual wheelchair bases must not include HCPCS code K0108 in addition to the base wheelchair code when a wheel- chair is constructed of titanium or for a ‘heavy duty package’ reflecting titanium construction materials. [Claims containing] HCPCS code K0108, reflecting tita- nium construction or ‘heavy duty package’ comprised of titanium components, are considered as incorrect
14 march 2017 | mobilitymanagement
coding — unbundling.”
Clayback contends that the December announce-
ment is yet another example of CMS altering its policies in a way that makes it more difficult for Medicare benefi- ciaries to obtain critically needed assistive technology.
“This is the most recent example of policy changes and re-interpretations over the past few years imple- mented by CMS and its contractors that eliminate access,” Clayback said in his letter to the industry. “This policy announcement prevents Medicare benefi- ciaries with disabilities from obtaining complex rehab technology (CRT), even if they are willing to pay for upgrades themselves.”
Beneficiaries Denied Access
In an NCART issue paper being distributed to industry advocates and policy decision makers, Clayback argues that the technology landscape was very different when the manual wheelchair base reimbursement amount was established in 1993.
“These capabilities and materials were not widely available in 1993, and for years suppliers have used a ‘not otherwise classified’ code to bill for these additional costs,” the issue paper points out. “And many payors, including Medicare, approved them. For Medicare, if suppliers provided and billed for such items, beneficia- ries could choose to pay the difference themselves in cases where coverage was denied, but not anymore.”
To ensure continued beneficiary access to the technological benefits offered by more recent func- tional improvements, the issue paper says CMS should rescind the new policy and issue a clarification to confirm that providers can continue to use the K0108 accessory code to bill for titanium K0005 (ultralight- weight) manual wheelchairs.
The issue paper also calls for providers to be able to use the K0108 code to bill for heavy-duty upgrades to the K0004 code (high-strength, lightweight manual wheel- chair), and the E1161 code (adult manual tilt in space wheelchair) codes.
“We have also reached out to CMS with our concerns and are pursuing other channels in the Congressional and advocacy arenas,” Clayback said. “We will keep you updated on our progress and next steps that may be required.” l

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