HC: What occurred in the power mobility sector after the award of competitive bidding contracts? MS: Quite a few providers won contracts for power mobility, but they only bid because they wanted to continue providing manual wheelchairs. They were not well versed in how to bill for power mobility; it’s different in regard to documentation requirements. It’s unfortunate for the beneficiary as well as the provider. It is a complicated system, and even before competitive bidding, documentation error rates were 80 to 85 percent. Noncontract providers have been inundated with calls from beneficiaries asking where to go. It’s a burden that CMS has placed on them. Basically, they’re driving customers away from their stores while educating beneficiaries on competitive bidding. HC: Did Medicare consider whether providers had the experience to handle PMD services? MS: You would think there would be a vetting process to ensure those who were bidding were actually going to provide the product and were capable of handling the back-end paperwork to pay for the equipment. CMS doesn’t seem to be too concerned. For instance, some PMD cushions fall under competitive bidding, but some providers who won bids don’t even have a line of credit with the manufacturer who supplies these cushions. There’s frustration that CMS hasn’t done its due diligence in regard to these contract winners. HC: How complicated is the documentation process? MS: Power mobility rules and regulations are scattered throughout the local coverage determinations (LCDs) and other documents put out by Durable Medical Equipment Administrative Contractors (DME MACs) and CMS. We’re probably going to be doing a course for a buying group soon. A lot of providers don’t realize that not everything is in the LCDs. There are signature requirements, legible identifier requirements and a date-stamp sequence showing when a provider received documents—a lot of little things that can trip up the process. HC: Is there confusion among PMD subcontractors regarding what they can or can’t do in the process? MS: Home assessment is one issue that has not been brought to the forefront. The DME MACs and the Competitive Bidding Implementation Contractor (CBIC) have stated that these assessments are supposed to be done by the contract supplier only. Unfortunately, I’m not seeing that in many cases. HC: What happens when a subcontractor does this? MS: I think for the time being CMS doesn’t have a way to deal with it. It’s an issue, but they’re not paying much attention right now. Some providers not doing home assessments according to proper instructions could face revocation of their contracts. HC: Are there other issues? MS: Yes, repairs in regard to competitive bidding. Contract winners don’t want to do the repairs on patient-owned equipment, although a noncontract provider can still do repairs. But many noncontract providers don’t want to do repairs because they have to accept a single payment that is far too low. HC: How do you feel about items being termed medically necessary? MS: CMS purposely made this complicated. I know that’s a strong opinion. But when utilization increases occurred in the early 2000s, CMS needed to put a stop to it. They got rid of the one-page Certified Medical Necessity (CMN), and now they require the provider to jump through hoops. CMS often doesn’t consider the needs of the beneficiary. It focuses on what’s wrong with the documentation so the claim can be denied.
