At a time when it takes between 22 and 27 hours of direct labor time to provide a complex power wheelchair, a paper trail is crucial for complying and getting reimbursed by Medicare. Home care providers must fully document the important services they provide to Medicare beneficiaries.
In January, AAHomecare was instrumental in helping schedule a meeting with members of the industry and the Department of Health and Human Services' Office of the Inspector General (OIG). The subject of this meeting was the October 2007 OIG report that compared Medicare power wheelchair payments to consumer Internet prices.
During this exchange, representatives of the OIG said they will be conducting further analysis of power wheelchair reimbursements in 2008. Specifically, new studies will look at service-related costs associated with providing standard power wheelchairs (HCPCS code K0823) and a complex rehab code, as well as examine the service-related costs associated with furnishing complex rehab power wheelchairs.
As part of its research, the OIG plans to obtain invoices that reflect all discounts and rebates in order to gain a better understanding of suppliers' absolute costs of goods associated with power mobility. They also plan to study the non-product-related costs and services components that relate back to providing a power wheelchair.
The OIG indicated they expect that copies of patients' files will show all of the services provided to the individual based on the documentation therein.
Unfortunately, these retrospective audits performed by OIG may not accurately calculate service and non-service costs as they compare to Medicare allowables. Our coding system currently bundles equipment and service cost together.
Thus, we could be fighting an uphill battle since the assumption that the OIG will be working under is: “If it's not documented, it didn't occur.” The danger of any OIG study that does not accurately account for the services supplied by DME companies will likely be new legislation reducing Medicare reimbursements.
The challenge we face as an industry is how to begin more comprehensive documentation.
“If we are to illustrate the numerous value-added steps taken when providing power mobility devices, providers must document more comprehensively within the patient file,” said Georgie Blackburn, Jurisdiction A/B Advisory Council member and vice president of government relations for Blackburn's in Tarentum, Pa.
“By documenting our actions, why they are necessary, the time involved, and the positive outcome achieved, the data will prove our service equates to dollars and is something that cannot be provided through Internet purchasing,” Blackburn said.
And because we do not already document every touch with a patient like physicians and other clinicians, we must initiate the process of helping the OIG understand and quantify the service-related costs by illustrating the general operational and overhead costs that are inherent to any HME supplier. These include general overhead and fixed operating costs, the referral process, supplier costs, service costs and processes inherent in providing any power wheelchair to a consumer.
We must make clear the distinction between suppliers that provide power wheelchairs and related services to Medicare beneficiaries and Internet wheelchair vendors.
Materials have been developed and studies are being conducted to identify and quantify the price of service. The association also extended an invitation to OIG to visit a complex rehab provider. Furthermore, we encourage the OIG to select and configure a power wheelchair through an Internet vendor.
But our industry must, from this point forward, make a record of the important work we do and begin to implement documentation policies that will fairly represent the steps in the service and delivery for complex rehab for each individual client.
Tyler J. Wilson is president and CEO of the American Association for Homecare, Alexandria, Va. He may be reached by e-mail at tylerw@aahomecare.org. For more information about the association, visit www.aahomecare.org.
