Industry to CMS: Delay PMD Code Changes

ATLANTA–As the Oct. 1 implementation date for new power
mobility device codes approaches, the industry has renewed its
efforts in asking CMS for a delay.

According to Michael Reinemer, vice president of communications
and policy for the American Association for Homecare, the group’s
Rehab and Assistive Technology Committee planned to send an e-mail
to CMS Administrator Mark McClellan by the end of the day Friday
asking him to postpone the changes in order to “work out some of
the issues” surrounding the new HCPCS codes.

One of those issues involves fee schedules for the 64 codes,
which were developed by the SADMERC and introduced in June. But
AAHomecare and other stakeholders said a product classification
list released by the SADMERC last month is riddled with errors, and
that list must be corrected before prices are calculated (see
HomeCare Monday, Aug. 14).

“These flaws are extensive; one large manufacturer of PMDs
reports that as much as 50 percent of its products may be miscoded
based on the information that it submitted to the SADMERC,” the
association said in comments to CMS. “CMS cannot begin to develop
fee schedules until all PMD models have been properly aligned
within codes. Otherwise, the data used to develop the payment rates
would also be flawed.”

Following the SADMERC’s product classification list, CMS also
published a document containing information it has gathered to
establish fee amounts for the PMD codes based on three pricing
sources: the median MSRP, the median wholesale price and a median
price derived from Internet Web sites. But because the pricing
source list is based on the product classification list, the
association pointed out, this document also is incorrect and needs
to be reissued.

What’s more, the association said, Internet prices are an
“inaccurate data source” and will skew the median price downward
because they do not reflect the service and administrative costs
that Medicare enrolled suppliers incur. The use of such pricing
data will result in “inaccurate Medicare payment for these products
and create what may be insurmountable barriers to access for
beneficiaries,” the association said.

In an Aug. 31 letter to Pride Mobility providers, Dan Meuser,
president of Pride USA, said although the industry has maintained
“a good dialogue” with CMS about the new codes, the PMD local
coverage determination and the fee schedules, “it is clear that the
timeframe for implementation, along with various aspects of the LCD
are unreasonable.”

Along with concerns about PMD pricing, according to Meuser, the
industry does not have time to adapt to the changes by Oct. 1
because:

• Quality U.S. manufacturers do not have products available in
  the low-end code, and quality providers do not presently provide
  them.
• It is impossible to educate physicians in a two- to three-week
  timeframe.
• It is estimated by some billing software companies that 80 to
  90 percent of rehab providers may not be prepared to bill by that
  date.

Meuser also said that the LCD “downcodes” for power wheelchairs
are contrary to the recommendations of the Techinical Expert Panel,
commissioned by CMS to help in developing the codes.

On Friday, members of the 14-member TEP upped the ante in a
letter to HHS Secretary Mike Leavitt.

“Most of our critical recommendations were ignored or modified
to the point that they no longer represent our intent as panel
members,” the letter stated. “Though we are disappointed that CMS
ignored much of the advice from these experienced clinicians,
suppliers, manufacturers and scientists, we are primarily concerned
that CMS’ final decision will have a devastating impact on the
health and well-being of tens of thousands of people with
disabilities.

“We strongly urge that CMS work diligently with the TEP
Workgroup and other stakeholders in this process to fix the
significant problems with the interpretation of the new PMD code
set before they are implemented.”

To view the product classification list, click here. To download the pricing source
document, click here.

To read the full body of AAHomecare’s comments on power
wheelchcair pricing sources, visit www.aahomecare.org.