CMS debuts 64 new codes for wheelchairs, scooters

Sunday, June 11, 2006

WASHINGTON - When CMS released 64 new power mobility codes June 2, it provided so few details that the industry didn't know what to make of them. What's still missing: additional testing requirements, coverage criteria and pricing.

"I think what we've got here is a skeleton," said Simon Margolis, who sat on a 14-member technical panel that provided CMS with recommendations for the new codes. "We have to see what happens when they start hanging some flesh on it."

The codes, which go into effect Oct. 1, 2006, are organized into six wheelchair and two scooter groupings based on functionality and performance. Each group has sub-divisions based on "patient weight capacity and/or powered seating system capability."

Additionally, the codes--61 codes plus three miscellaneous codes for a total of 64--include not only the type of "base" but also options and accessories.

It won't be until the testing requirements, the coverage criteria and pricing are released, however, that the industry will be able to put the new codes into context, said Cara Bachenheimer, vice president of government relations for Invacare.

"It's a good overall framework, but we can't really assess the final impact on beneficiaries and their ability to access these products until these holes are filled in," she said.

There's still enough information in the new codes to give the industry some pause. The codes are "sliced and diced" pretty thinly, said Sharon Hildebrandt, executive director of NCART. For example, one of the few differences between the codes in two of the groups is speed and range, industry sources said.

"The question, from a medical policy standpoint is, how do you distinguish that much between those two levels of products?" Bachenheimer asked.

On the plus side, the codes seem to be set up in way that, when CMS applies gap-filling methodology, it should come out with appropriately priced products, Margolis said.

"Because there's a difference between a standard captain's chair and a standard sling seat and back chair, for example, we won't get underpaid for the sling seat and overpaid for the captain's chair," said Margolis, vice president for clinical and professional development for National Seating & Mobility. "Right now, with the K0011 code, everything is lumped in together, and if there's no differentiation, it goes to the least-common denominator."

Implementation of the 64 codes for power mobility devices will proceed as follows, according to industry sources and CMS's Web site:

- As early as last week--The SADMERC planned to issue more detailed instructions on the testing requirements for the new codes.
- Later this summer--The DMERCs and CMS are scheduled to follow up with an LCD and a fee schedule, respectively. The DMERCs must give 30 days advance notice before implementing an LCD, but the industry's not sure whether they will provide a comment period, Bachenheimer said. "They may consider last year's draft LCD as the draft that they got comments on," she said. "We don't necessarily agree with that, because there were a number of serious issues in that original draft."
- Aug. 1, 2007--Manufacturers have until this date to have their equipment re-tested by an independent testing laboratory based on new testing requirements.
- Oct. 1, 2006--The new codes go into effect.
- Jan. 1, 2008--Fee schedule amounts will be revised, as appropriate, to reflect any changes made to product classification due to re-testing. Pricing will be implemented on this date.

Seth Johnson, vice president of government affairs for Pride Mobility Products, said he's "a little concerned with the timeframe" for implementing the new codes.

"This is a significant change to the industry," he said. "We're going to 64 codes from five--one power scooter code and four power wheelchair codes. Think of all the provider and physician education that needs to take place."