ALEXANDRIA, Va.--Despite CMS' recent revisions, there are still numerous problems with its new PMD pricing, the American Association for Homecare said in a Nov. 20 letter to the agency.

The association identified the following issues with the fee schedule, which took effect along with new coding and coverage criteria on Nov. 15:

--CMS' methodology contains discrepancies. The agency excluded 250 of 443 models classified by the SADMERC from its computations. Most of the excluded models are from major American manufacturers Hoveround, Invacare, Pride Mobility and Sunrise Medical. In contrast, the vast majority of models from major foreign manufacturers Merits and Shoprider were included. Consequently, fee schedule amounts are understated. "We believe the correct approach would be to include all SADMERC-listed models in the computations," the letter stated.

--In some cases, the manufacturers suggested retail prices that CMS used are much lower than the MSRPs that manufacturers submitted to the SADMERC--four Hoveround models, for example, are understated by as much as $970 to $1,320.

"We are also troubled by the adjustment to MSRPs for batteries," the letter said. "We understand that, while a number of manufacturers excluded batteries from the base MSRPs they reported to the SADMERC, CMS deducted the value of batteries for all models."

--CMS has not consistently reviewed the payment amounts for all PMDs. While the agency has adjusted some pricing for devices in Group 3, it has not for those in Group 2. For example, CMS priced the K0825 Group 2 HD code only $3.50 above the K0823, while the agency adjusted the K0851 Group 3 HD payment $547 higher than the amount for K0849. "The agency's seemingly inconsistent approach further underscores the importance of the agency disclosing its rationale for all MSRP adjustments," AAHomecare wrote.

--Moreover, "CMS should use available historical data for gap-filling, consistent with past practices."

--CMS must address "numerous mathematical errors," which have resulted in pricing overall that is 3 percent lower than it should be.

--While it appreciates the changes CMS has made in the fee schedule for Group 3 PMDs, AAHomecare said "multi-power option devices under Group 3 require further adjustment." The association recommended that CMS add the current allowable for E2320 to the proposed allowable for the Group 3 multi-power codes.

The letter also asked CMS to explain what criteria it used to determine which products were included and why that criteria was used; to describe its reasoning in adjusting the reported MSRP for some PMDs but not others; and why it made different adjustments to the MSRP for different products.

"The lack of explicit information on CMS' approach to developing the fee schedules seriously limits our ability to evaluate the impact of CMS' action," AAHomecare concluded.

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