Propelled by a flurry of potential reimbursement cuts that could imperil providers and beneficiary access alike, the National Coalition for Assistive
by Susanne Hopkins

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.

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. 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 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 be conducted at the Georgia
Institute of Technology (Georgia Tech) in Atlanta 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 Capitol 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.ncartcoalition.org) 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 last
year 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.

Added Hildebrant, “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 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 in January with the OIG,
AAHomecare and NCART during which OIG representatives indicated the
agency would audit provider claims this year to calculate
service-related costs for both complex and standard PWCs.

Indeed, many providers did receive “Documentation
Request” forms from the OIG asking for information on
“complex rehab” and K0823 power mobility device codes.
The deadline for returning the forms was March 28, and AAHomecare
was hopeful providers who got them explained carefully to the OIG
the service-intensive nature of providing power wheelchairs.

“Rehab providers should be aware that the OIG is
conducting these studies,” said Tim Pederson, chair of RATC
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 begin compiling data from their
billing systems, chart notes and computer calendars to give a
complete picture of services, and AAHomecare is encouraging rehab
providers to document as much detail as possible in the patient's
record about interactions with the patient.

The association said it is “extremely concerned” the
OIG's efforts will not accurately quantify the full costs of
providing PWCs because the HCPCS coding system does not require the
collection of such data.

What's more, AAHomecare warned: “Government studies that
suggest that limited services are being provided to Medicare
beneficiaries who are furnished power wheelchairs could lead to
another round of reimbursement cuts for power wheelchair
payments.”