Medicare rocks rehab with change
BALTIMORE - Between late August and mid-September, Medicare unveiled so many unexpected and potentially overwhelming changes to how rehab providers do business that the industry was left with its head spinning.
Not only did Medicare announced plans to drop CMNs for power wheelchairs and scooters, but it also released a "distressing" draft local coverage determination (LCD) and issued new codes and testing requirements wheelchairs.
In late August, CMS hit the industry with an "unexpected" announcement that it planned to replace CMNs for power chairs with prescriptions and also require the provider to keep on file the prescribing physician's medical records. The switch is scheduled to take effect Oct. 25.
On Sept 14, the DMERCs then issued a draft local coverage determination for power mobility devices that, while it contained "a few good nuggets of information," raised serious questions, especially about in-home use, said Cara Bachenheimer, vice president of government relations for Invacare.
That same day, 63 new codes and testing requirements were posted on Palmetto GBA's Web site. In February, CMS created 49 new codes and testing requirements to take effect Jan. 1.
"The combination of these two things," Bachenheimer said of the draft LCD and new codes, "it's overwhelming, and not in a good way."
Both the draft LCD, for which comments will be accepted until Oct. 31, and the new codes will take effect Jan. 1.
Since the changes have been announced, providers have been scratching their heads over how they'll collect supporting documentation from physicians. Per the final interim rule, they must collect information on patient history, physical examinations, diagnostic tests, summary of findings, diagnoses and treatment plans.
"The amount of information that has to be conveyed to the providers is incredible," said Sharon Hildebrandt, executive director of the National Coalition for Assistive and Rehab Technology. "I can't see that doctors are going to be willing to provide all of that information. And so that's going to leave the provider in a quandary, because if the physician is not willing or able to provide all of the documentation, where does that leave the provider when a beneficiary needs the equipment?"
The industry isn't comforted that CMS will only ask for supporting documentation under a review or audit, because a provider can't bill Medicare until he has that information on file.
To boot, CMS will have to conduct a large educational campaign to school physicians on providing supporting documentation, said Seth Johnson, director of government affairs for Pride Mobility. The planned Medlearn Matters article, Sept. 13 Special Open Door Forum and the draft LCD may not be enough.
Providers also have concerns about the Oct. 25 implementation date and the 30-day timeframe for evaluations and submitting claims.
The rehab industry had high hopes that the draft LCD would clear up some of these uncertainties. The draft does address concerns that physicians will not provide suppliers with the appropriate supporting documentation by outlining a series of questions that physicians should answer in their notes.
The draft also clarifies in-home evaluations by stating that HME providers can determine whether patients can maneuver a power mobility device in their home upon delivery.
Still, the draft, which makes a "bright line distinction" between consumer mobility and high-end rehab, has a "lowest-common denominator objective," Bachenheimer said.
"The most distressing thing about the medical policy is that there's clearly an intent for beneficiaries to receive products that are only appropriate to use in the home," she said.
Neither the rule nor the draft LCD may even matter with the introduction of new codes and testing requirements, Bachenheimer said.
"That was the one piece of the puzzle that was set," she said. "Now we're back to square one."
Invacare has already gone through the expensive and time-consuming process of testing some 30 products based on the 49 codes and testing requirements. The company has even received code verifications for most of its products.
"This document says those are null and void, but they're saying, 'We're going to look at your applications,'" she said. "It's unbelievable."
CMS has extended its product testing deadline, originally set for Sept. 1, to Nov. 15. The agency said it would try to determine proper code placement for products already tested.