As in years past, the Rehab and Assistive Technology Council at the American Association for Homecare will actively pursue the overarching goals set earlier this year: to ensure Medicare beneficiary access to rehab and assistive technology products through the development of appropriate coverage, coding and payment policies, and to increase the quality standards for rehab providers.
A key regulatory development related to our goals occurred on April 5 when CMS published the final rule, “Conditions of Coverage for Payment of Power Mobility Devices.”
The rule finalizes many of the requirements of the interim final rule published last fall, including a mandatory face-to-face examination of the beneficiary by the treating physician or practitioner, elimination of the certificate of medical necessity and the establishment of new documentation requirements.
The final rule also incorporated one of the changes that was widely recommended by the industry: an extension of the timeframe for the physician to provide the supporting documentation to the mobility supplier to 45 days from the completion of the face-to-face exam. This timeframe was 30 days in the IFR.
It is important for providers to know that until the final rule goes into effect on June 5, the 30-day timeframe for the prescription and supporting documentation from the physician remains in effect. For claims with a date of service on or after June 5, the 45-day timeframe will apply.
The RATC continues to seek additional clarity about documentation requirements since that was not addressed in the final rule. The short-term goal is to continue to press CMS and the DMERCs to issue guidance in order to provide a common understanding of the documentation requirements for both mobility providers and physicians.
The RATC also will focus on several other priority issues this year, including:
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Revision and implementation of new power mobility device HCPCS codes and local coverage determination. The council is monitoring closely the development of new PMD codes and the revised LCD that will tie the national coverage policy to the new codes. As of this writing, the new codes and testing requirements are expected this spring.
The RATC will work to ensure that these codes and the LCD preserve patient access to the most medically appropriate equipment, services and technology.
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Gap-filling alternative/fee schedule. The gap-filling methodology currently in use by CMS to develop new fee schedules is flawed. That results in inadequate reimbursement for medically necessary equipment.
The council is working to educate CMS and Congress about the problems that result from a straight application of gap filling, and is strongly recommending the adoption of the Muse & Associates 1992 proxy year alternative.
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Capped rental language in the president's FY 2007 budget request. The president's fiscal year 2007 budget proposes to “reimburse for short-term power wheelchair usage based on actual time used versus paying up front at the full purchase price.” The RATC will educate members of Congress on the need to preserve the first-month purchase option for power wheelchairs.
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Quality standards. The council strongly supports the adoption of rehab technology product-specific standards. As CMS develops the final quality standards for home medical equipment, the RATC will work with CMS on the adoption of such product-specific standards.
The RATC meets monthly to discuss the latest information that affects this segment of home care and to develop or modify strategies in support of positive outcomes. If you are interested in becoming more involved in the efforts that affect mobility providers, contact AAHomecare today. The association is committed to ensuring beneficiary access to rehab and assistive technology products and services.
Also, remember that this is an election year. Mobility issues — and all home care issues — must be front and center in every congressional district across the U.S.
Seth Johnson is chair of the American Association for Homecare's Rehab and Assistive Technology Council, serves on the association's board of directors, and is vice president of government affairs at Pride Mobility Products in Exeter, Pa. For more information about AAHomecare, call 703/836-6263 or visit www.aahomecare.org.
