ALEXANDRIA, Va. — It went down to the wire, but AAHomecare’s Rehab and Assistive Technology Council (RATC) met its April 1st deadline and submitted its second, and possibly most complex, batch of codes to CMS, said chair Rita Hostak.
The RATC, assigned to the labor-intensive task of developing a new HCFA Common Procedure Coding System (HCPCS) for the Centers for Medicare and Medicaid Services (CMS), submitted more than 20 HCPCS code applications at the beginning of April, the agency’s annual deadline. The second submission of codes were in the categories of alternative positioning, ambulatory products, bath safety, configured seating, manual wheelchairs, power wheelchairs, and wheelchair accessories.
The RATC submitted the first code applications last April for adult tilt-in-space and pediatric mobility products and accessories to pediatric mobility products, which were implemented January 1, 2003. CurrentlyNext, the RATC is prioritizing the hundreds of codes still needing review for its next third batch, with a possible focus on adaptive devices.
As this year’s April 1 deadline approached, Hostak said, some members of the RATC task force questioned whether the timing was right to submit the K0011 code for power wheelchairs. Due to comments by CMS administrator Tom Scully regarding power wheelchair utilization growth and the efforts to impact that growth, he had reported that DME had realized a 28% growth for all wheelchairs and a 54% jump in power chairs alone.
“(RATC members) were concerned that the administration’s focus on one code would overshadow the hard work put into the overall coding proposal,” Hostak said. “Ultimately the group agreed that appropriate coding of power mobility was, in fact, part of the overall solution regarding power wheelchair utilization.”
The RATC has been charged with the duty of identifying coding deficiencies in the current Medicare HCPCS system due to technology changes and recent industry growth. The RATC task force is trying to refine the hundreds of codes due to the coming adoption of the Health Insurance Portability and Accountability Act (HIPAA) in October. All private and public payors will use the national HCPCS codes, instead of local codes, once HIPAA goes into effect.
After discussion and review of the input the RATC received from the rehab industry by sending two on-line surveys to clinicians and Assistive Technology Suppliers (ATS), Hostak said the group agreed that the current K0011 code was too vague and that varying types of technology were currently clustered into the one code. The RATC, she said, then came to a unanimous decision to submit the code applications.
The code change will break down the K0011 to pay for more options and high-end rehab mobility, Hostak said. “The (K0011) needed to have a level of detail and industry focus,” she said.
The K0011 has been divided into three new proposed codes, outlining the varying types of technology, Hostak said.
Aren’t they suggesting that the K0011 be split three ways? If so, how so? And aren’t we going from K-codes to E-codes on this?
Hostak said it was critical for the RATC to meet the April 1 deadline this time around due to the importance of the power mobility issue and the fact that HIPAA will be implemented in six months. Based on how the coding application process works, she said, submissions must be in by April 1 each year or the application will not be reviewed until the following year.
“There has been a tremendous emphasis and a lot of focused energy by a number of different groups in an effort to ensure that the majority of the items can have HCPCS codes by this January,” Hostak said.
The code applications still must be reviewed by the CMS HCPCS workgroup, made up of DMERC, SADMERC representatives and Medicaid representation, Hostak said., and, tThrough several public meetings, a final preliminary decision is forwarded on to an Alpha-Numeric Editorial Panel, which reviews the codes letter and number placement, she said. Break up the preceding sentence.
Final decisions regarding HCPCS applications, she Hostak said, are released in November for implementation the following January.
There is a 90 day grace period, in most situations, Hostak said, that allow the use of old codes before having to implement the use of new ones, Hostak said. In that case, she said, suppliers do not have to utilize the new codes until April 1 of the year the code was implemented.
Along with the code determination, Hostak said each code is also assigned a payment category such as capped rental, inexpensive or routinely purchased, a pricing methodology legislated by Congress containing deflation and inflation elements. While all payers are required to use the HCPCS codes by October 2003, they are not held to the Medicare fee schedule or Medicare coverage policies.
While this is just the second submission from the RATC in their 19-month existence, Hostak said the task force has been more efficient and effective by using manufacturers and suppliers to help develop code definitions and descriptors. The mission to identify coding deficiencies in the current Medicare HCPCS system, primarily rehab products, has been quite an undertaking, she said, but also necessary.
“It’s been a real challenge,’ said Hostak. “But it’s the only way. It’s the only process of getting the coding in place.” HME