NCART Commissions Complex Rehab Study; AAH Warns of OIG Audits

WASHINGTON–Propelled by a flurry of potential reimbursement
cuts that could imperil providers and beneficiary access alike, the
National Coalition for Assistive and Rehab Technology has
authorized a two-year study of services, costs and outcomes
associated with providing rehab technology, officials said
Friday.

Complex rehab has been included in both rounds one and two of
national competitive bidding. Last fall, in a report the industry
decried as misleading at best, the Health and Human Services Office
of Inspector General said Medicare could save millions on power
wheelchairs if the government reimbursed them at rates available on
the Internet. (See HomeCare
Monday, Nov. 5, 2007.)

In addition, Congress has surfaced the idea of eliminating the
first-month purchase option for power chairs, a provision President
Bush included in his 2009 budget.

While NCART has worked to stem the tide of looming cuts–most
notably through support of H.R. 2231, which would carve out complex
rehab from competitive bidding–its efforts have been stymied
because of lack of data, according to Sharon Hildebrandt, executive
director.

“One important element we are lacking as an industry in our
attempts to change and modify payment and coverage policies is
independent and credible data regarding the non-product related
costs associated with the complex rehab service delivery model,”
Hildebrandt wrote in a letter sent Friday announcing the study. “We
have good tools that anecdotally describe the processes, and
self-reported surveys regarding the costs. But we do not have
independent studies of the costs and outcomes of complex
rehab.”

Hildebrandt said the study will take place under the auspices of
the Sam Schmidt Paralysis Foundation and will be conducted at
Georgia Tech University and the University of Buffalo.

Doug Westerdahl, chair of NCART’s Medicaid committee and CEO of
Monroe Wheelchair in Rochester, N.Y., said the need for concrete
data is critical.

“Right now, we go to Capital Hill or the OIG or CMS or whomever
and we tell them we spend all this time [providing rehab], but the
studies we show are all our own. The universities will be outside
institutions that will be validating the time,” he said.

Hildebrandt said NCART will use the information “to seek higher
reimbursement and distinct coding and coverage policies for complex
rehab devices.

“We believe the information resulting from this study will also
be of value at the state level as [providers] battle attempts to
cut back on reimbursement and restrict coverage,” she added.

NCART also has been seeking ways to help providers deal with
Medicaid reimbursement issues. The organization recently revamped
its Web site (www.ncart.us)
to include links to the state Medicaid systems, including fee
schedules and coverage guidelines by state.

“One of the huge problems on the Medicaid side is that very
little information gets shared,” said Westerdahl. “Once this gets a
little headway, I am hoping that it becomes more and more of a
resource for not only sharing fee schedules and guidelines but
other issues where we can help each other.”

In addition to aiding providers in dealing with Medicaid, the
study could also help muster support for H.R. 2231. Introduced in
May by Reps. Tom Allen, D-Maine, and Ron Lewis, R-Ky., the bill is
in a holding pattern with 37 cosponsors and no Senate companion. To
move forward, the carve-out measure needs many more sponsors or to
be attached to another bill, Westerdahl said.

Findings of the study, if they come in time, could help. Said
Hildebrandt, “We need to do more to educate CMS and the Congress
about complex rehab assistive technology. Specifically, we must
demonstrate to them that the services related to providing complex
rehab and assistive technology are far in excess of those services
associated with providing traditional DME. Only by proving this
premise can we truly distinguish ourselves and obtain the different
and separate treatment we seek.”

The American Association for Homecare also said last week that
its Rehab and Assistive Technology Council is “working to develop a
framework to calculate the service and overhead costs of providing
the full range of power wheelchairs to Medicare beneficiaries.”

The project was sparked by a meeting with the OIG, AAHomecare
and NCART during which OIG representatives said the agency would
audit provider claims this year to calculate service-related costs
for both complex and standard PWCs. The association said the OIG
will study K0823 and a complex rehab code likely to be K0861.

“Rehab providers should be aware that the OIG is conducting
these studies and may be requesting claims data and patient records
for its report,” said Tim Pederson, chair of RATC and president and
CEO of WestMed Rehab in Rapid City, S.D. “Unfortunately, the OIG’s
work will be looking backwards at claims that will not likely
demonstrate the full range of services rehab providers
provide.”

Pederson urged providers to compile data from their billing
systems, chart notes and computer calendars to give a complete
picture of services, and AAHomecare suggested that providers
immediately begin documenting in detail in the patient’s record
information about patient interactions.