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.”
