Third PMD LCD Eliminates Independent Transfer Requirement

BALTIMORE–While it’s still not exactly what the industry might
call a charm–and while new pricing cuts are still scheduled for
Nov. 15–the third version of the local coverage determination for
power mobility devices removes some language and addresses other
concerns that had troubled stakeholders since its release in
August.

Last week, the Medicare DME Program Safeguard Contractors issued
a newly revised LCD, removing the “unable to independently stand
and pivot to transfer” requirement for Group 3 chairs.

The revised coverage criteria now states that the beneficiary’s
mobility limitation must be due to “a neurological condition,
myopathy or congenital skeletal deformity.”

When the LCD was originally released, many in the rehab
community expressed concerns that the interpretation of
“independent transfer” could include people who face a severe
struggle to transfer themselves without assistance.

Stakeholders also complained that the first LCD would put
patients in the cheapest and lowest-quality equipment. In response,
the PSCs announced in September that implementation of the LCD
would be delayed from Oct. 1 to Nov. 15. The LCD was also revised
to eliminate the “least costly alternative” determination, which
would have resulted in automatic downcoding to a Group 1 power
wheelchair for patients not meeting coverage for a Group 2 or
higher chair (see HomeCare Monday, Sept. 26).

Issued Wednesday, the third LCD goes a step further, addressing
additional industry concerns.

Another change in the latest version is that single power option
or multiple power option wheelchairs in Groups 2 through 5 are
eligible for Advance Determination of Medicare Coverage, regardless
of whether a power seating system will be provided at the time of
initial issue.

“This will permit advance determination for a patient with a
progressive neurological disease, such as amyotrophic lateral
sclerosis or multiple sclerosis, who does not yet need a power
seating system but the documentation from the face-to-face exam
supports the need for such a system in the future,” the PSC summary
stated.

According to the American Association for Homecare, which had
detailed problems with the LCD and presented them to CMS and the
Medicare contractors, the revisions “largely address our
concerns.”

“We’re pleased that the DMERC medical directors and CMS have
listened to those concerns and made these changes to the coverage
policy,” said Seth Johnson, chairman of AAHomecare’s Rehab and
Assistive Technology Council, and vice president, government
affairs, for Exeter, Pa.-based Pride Mobility. “Clearly, we still
have a lot of work to do to get the fee schedules corrected but
this is a positive development.”

To view the revised PMD LCD, click here.