CMS limits K0108 for manual wheelchairs

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Friday, February 10, 2017

WASHINGTON – CMS has taken away a Medicare beneficiary’s “right to choose,” now that providers aren’t allowed to use K0108 for titanium or heavy duty upgrades for manual wheelchairs, industry stakeholders say.

In a joint article on Dec. 15, the DME MACs state that the codes for manual wheelchairs—K0001 through K0009—have always included the cost of these upgrades.

“Suppliers billing for manual wheelchair bases must not include HCPCS code K0108 in addition to the base wheelchair code when a wheelchair is constructed of titanium or for a ‘heavy duty package’ reflecting titanium construction materials,” they state. “Claim HCPCS code K0108 reflecting titanium construction or ‘heavy duty package’ comprised of titanium components are considered as incorrect coding-unbundling.”

The DME MACs state this has been the case since the codes were developed in 1993.

It has been common practice among providers to use K0108—“wheelchair component or accessory, not otherwise specified”—for titanium and heavy duty upgrades on complex manual wheelchairs. Because the DME MACs have labeled this practice “unbundling,” that’s no longer an option, stakeholders say.

“The article claims that by using the K0108, a provider would be ‘unbundling’ charges, which is not allowed,” said Claudia Amortegui, president of The Orion Consulting Group. “They also then cannot bill the extra charge as an upgrade. This philosophy would go against the principals of the upgrade provision. Simply put, the end-users’ right to choose has been taken away, if they want to pay the difference to obtain specific features and options.”

Now the only choice providers have is to bill non-assigned for manual wheelchairs with titanium and heavy duty upgrades, leaving beneficiaries to pay upfront for the total cost of the chair and to try to wrangle reimbursement for the chair, but not the upgrades, from Medicare.

“It’s unfortunate,” said John Goetz, director of government affairs for Permobil. “A lot of people can pay the difference, but they can’t pay the whole amount upfront.”

NCART has formed a work group and developed an issue paper in response to the change. It is reaching out to CMS to express its concerns and is pursuing “other channels in the congressional and advocacy arena,” it stated in a bulletin to members.

In the issue paper, NCART pushes CMS to rescind the change, and issue a policy clarification stating suppliers can use K0108 to bill for titanium for wheelchairs for K0005, and can use K0108 to bill for heavy duty upgrades for K0004, K0005 and E1161.