CMS Issues Unreasonable Billing Instructions for Accessories Used With Complex Power Wheelchairs

January 25, 2016

CRT Providers and Manufacturers,

Late this past Friday CMS posted instructions to Medicare providers for billing accessories used with Group 3 Complex Power Wheelchairs in light of the “one year delay” passed by Congress at the end of 2015.  The text of the announcement is as follows:

Implementation of Section 2 of the Patient Access and Medicare Protection Act (PAMPA)

The Patient Access and Medicare Protection Act (PAMPA) was recently signed into law.  Section 2 of PAMPA mandates that adjustments to the 2016 Medicare fee schedule amounts for certain durable medical equipment (DME) based on information from competitive bidding programs not be applied to wheelchair accessories (including seating systems) and seat and back cushions furnished in connection with Group 3 complex rehabilitative power wheelchairs.  Group 3 complex rehabilitative power wheelchair bases are currently described by codes K0848 through K0864 of the Healthcare Common Procedure Coding System (HCPCS).

Although this change is effective January 1, 2016, changes to the Medicare claims processing system cannot be implemented any sooner than July 1, 2016.  Until these changes are implemented, payment for these items will be based on the adjusted fee schedule amounts.  Suppliers can submit claims for these items with dates of service on or after January 1, 2016, but payment will be based on the adjusted fee schedule amounts.  On or after July 1, 2016, suppliers can adjust previously paid claims with dates of service on or after January 1, 2016, to receive the full fee schedule amount.

Additional information, including a list of HCPCS codes for accessories affected by this change, as well as further instructions regarding the submission and processing of these claims, will be provided in the coming months.

This published billing policy violates the intent of the year-end Congressional legislation and unfairly places significant burdens on CRT providers which will compromise their ability to provide continued access to the complex rehab wheelchairs used by people with high level disabilities.

We are reaching out to CMS and to our Congressional champions to point out the unreasonableness of paying providers at reduced payment amounts for the next 6 months.  This is what the year-end legislation was to prevent.  It is also unreasonable to then require providers to have to “resubmit” 6 months of claims after July 1, 2016 to get paid the proper amount.

We will supply further updates as we have more information.

On a related note, we have been meeting with our Congressional champions to develop the CRT strategy and messaging for 2016 to obtain permanent legislative solutions to protect access for people with disabilities.  To kick off this important year we will be holding a “CRT Legislation Update” call for CRT Stakeholders on Tuesday February 9th at 4 PM ET to review our planned activities.  Additional call-in details will be provided next week.