The Centers for Medicare & Medicaid Services (CMS) has released its first coding recommendations following its May decision to cover powered seat elevation on power wheelchairs for Medicare beneficiaries.
The recommendations were part of CMS’s announcement of a Nov. 30 public meeting on Healthcare Common Procedure Coding System (HCPCS) codes.
In mid May, CMS said it would start covering seat elevation on both Complex Rehab Technology (CRT) and consumer power wheelchairs for Medicare beneficiaries. While the decision took effect immediately, CMS has not yet released information on coding or allowables for either type of power chairs.
CMS Suggests Two New Codes
Preliminary information announced by CMS the week of Nov. 6 provides a first glimpse at how the agency could approach seat elevation coding and allowables.
In the meeting notes, CMS said it was recommending eliminating the current E2300 seat elevation code and adding two new codes: “Complex rehabilitative power wheelchair accessory, power seat elevation system, any type,” and “Power wheelchair accessory, power seat elevation system, any type.”
CMS said, “The second code listed here, ‘Power wheelchair accessory, power seat elevation system, any type,’ describes only the seat elevation system and thus could be billed for use with a non-complex rehabilitative Group 2 power wheelchair base. CMS believes the establishment of this new accessory code may obviate the need for existing non-complex rehabilitative Group 2 codes that describe an integrated seat elevation system and a Group 2 power wheelchair base.”
Because of this, CMS also recommended eliminating the K0830 (Power wheelchair, Group 2 standard, seat elevator, sling/solid seat/back, patient weight capacity up to and including 300 lbs.) and K0831 (Power wheelchair, Group 2 standard, seat elevator, captain’s chair, patient weight capacity up to and including 300 lbs.) codes.
CMS Gives Preliminary Payment Recommendations
As for allowables, CMS said the CRT industry suggested that funding for seat elevation on CRT power chairs be compared to allowables for power tilt systems on CRT power chairs. But the agency disagreed.
“We do not believe this to be an appropriate comparison,” CMS said in its meeting notes. “Different mechanical components are used to effect seat elevation from seat tilt (for example, seat elevation may use a telescoping seat post or scissor-lift component, while tilt would use a hinged mechanism with a geared connection to the motor), and while seat tilt must accommodate an expected shift in the center of gravity from front to back, seat elevation only impacts the center of gravity in the vertical axis. For these reasons, we find that seat elevation is not comparable to any item with an existing fee schedule amount, and so the gap-fill approach is the most appropriate method for making a payment determination.”
To establish preliminary allowables for CRT seat elevation, CMS compiled a list of 20 CRT power chairs currently able to accommodate seat elevation and examined the pricing of those systems.
“The average price across the seat elevation systems we found would be classified in this code was $3,450.60,” CMS said. “The annual deflation factors are specified in program instructions, and the deflated amounts are then increased by the update factors specified in section 1834(a)(14) of the Act for DME. Based on these adjustments, the purchase price would be approximately $2,261.89.
“Under the capped rental rules for complex rehabilitative power wheelchairs, the rental price would be approximately $339.28 for months 1-3, and $135.71 for months 4-13 for a total of $2,374.94 for 13 months of continuous use.”
CMS said it had no determination for allowables for the second proposed code, explaining, “As an extensive review of evidence to determine the coverage criteria for power seat elevation equipment for non-complex rehabilitative power wheelchairs is not complete, we are unable to determine the appropriate universe of seat elevation equipment that may be covered as a Medicare benefit under this code and, for this reason, we are unable to develop an appropriate payment amount at this time.”
The agency noted the relatively wide range of seat elevation pricing — “from around $600 to over $2000” — for consumer power chairs.
What’s Coming Next
In response to the CMS announcement, NCART said in a Nov. 8 bulletin, “The NCART Coding Workgroup has reconvened following the announcement and is preparing testimony for the CMS hearing, which is scheduled for November 30, 2023. Comments will address questions and concerns related to both coding and pricing. NCART is also encouraging manufacturers, providers, clinicians, and other stakeholders to submit written comments.
“The public meeting provides an opportunity for stakeholders to offer further comments related to modifications to the HCPCS code set. CMS’ final coding, benefit category, and payment decisions are expected to be published on CMS’ HCPCS Web site in February 2024 and effective April 1, 2024.”
The CMS HCPCS code meeting will take place via Zoom, Thurs., Nov. 30, from 9 a.m. to 5 p.m. Eastern time. CMS is currently asking speakers (primary or five-minute presenters) to register by Nov. 14. After speaker registration closes, other attendees will be invited to register.