At the suggestion of The van Halem Group, Medicare Recovery Audit Contractor (RAC) Performant Recovery, will start recovering underpayments — incorrect reductions owed to HME providers — for wheelchair accessories and cushions supplied for Group 3 complex power rehab wheelchairs.
The recovery of those under payments is a long time coming. The Patient Access and Medicare Protection Act (PAMPA), which was passed in Jan. 1, 2016, mandated that competitive bidding-based adjustments to the 2016 Medicare fee schedule for certain DME items should not be applied to wheelchair accessories, including seating systems, as well as seat and back cushions supplied for Group 3 complex rehabilitative power wheelchairs (codes K0848 through K0864).
While the change went into effect upon PAMPA’s passage, Medicare could not implement changes to its claim processing systems until July 1, 2016. Until that time, Medicare based its reimbursement for those claims on the bidding-derived feed adjustments.
So, the RAC will apply the underpayment recovery to claims for those complex rehab accessories and cushions that were for dates of service running between Jan. 1, 2016 and June 30, 2016.
CMS billing policy caused considerable controversy and frustration at the time, and has been a nagging loose end for CRT providers. The RAC decided to make the rare underpayments after Wayne van Halem, president and founder of DME audit consulting firm The van Halem Group, suggested it do so.
“Many folks don’t know this, but the RACs are funded to find underpayments, in addition to overpayments,” van Halem explained. “And in this environment, every little bit helps!”