At a Nov. 30 meeting with officials from the Centers for Medicare & Medicaid Services (CMS), representatives from the Complex Rehab Technology (CRT) industry suggested the agency pause its plan to eliminate the K0830 and K0831 HCPCS codes.
The recommendation from NCART came during the second biannual HCPCS Coding Cycle public meeting, held by CMS to discuss its recommendations for Medicare coding and funding for power seat elevation on power wheelchairs, among other equipment.
CMS Announces Initial Coding Recommendations
CMS announced coding recommendations in early November. In May, the agency said it would begin covering power seat elevation for Medicare beneficiaries.
In a surprise twist, CMS said in May that it would cover seat elevation on Group 2 consumer power chairs as well as Group 3 Complex Rehab power chairs. The seat elevation initiative had been a CRT initiative, with the industry asking for coverage consideration only for Complex Rehab power chairs.
CMS’s preliminary coding recommendations suggested eliminating the current E2300 (Wheelchair accessory, power seat elevation system, any type) HCPCS code and adding two new codes.
The first code would be defined as “Complex rehabilitative power wheelchair accessory, power seat elevation system, any type.” The second code would be “Power wheelchair accessory, power seat elevation system, any type.”
The second code, CMS said, would apply to seat elevation on non-CRT power chairs. The agency said, “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.”
As a result, 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.
CRT Asks for a Pause
At the coding meeting, Julie Piriano, PT, ATP/SMS, VP, Clinical Education, Rehab Industry Affairs and Compliance Officer, Quantum Rehab, was introduced as the industry’s primary presenter and was given 15 minutes to speak. Piriano was followed by Bill Ammer (Ammer Consulting), Brad Peterson (VP of U.S. Sales, Amylior) and Peter Thomas (ITEM Coalition/Powers Pyles Sutter & Verville), who were given five minutes each to speak.
Piriano presented NCART’s recommendations based on CMS’s initial coding suggestions. NCART’s asked that CMS:
— adopt the seat elevation code description in the NCART code application;
— recognize CRT seat elevation as a stand-alone system akin to power tilt and/or power recline;
— require that CRT power seat elevation systems possess the minimum performance characteristics outlined in the NCART code application;
— reconsider a separate code for heavy-duty power seat elevation;
— reconsider the assertion that power tilt is not comparable to power seat elevation, while considering the ANSI/RESNA testing specifications for dynamic stability;
— reconsider power tilt “as a comparable DMEPOS item for which a fee schedule amount already exists when establishing a fee schedule for CRT PSE”;
— and pause the addition of a new code for standard seat elevation for now, while adding this discussion to a future coding meeting when the industry has more information.
NCART recommended that CMS hold off on eliminating the K0830 and K0831 codes.
More Info Needed on Group 2 Seat Elevation
Robert Hoover, M.D., MPH, FACP, Chief Medical Officer at CGS Administrators, said he didn’t understand the objection to eliminating those codes. Piriano replied that the industry needs to conduct additional research into seat elevation usage on non-CRT power chairs.
Because that work hasn’t yet been done, Piriano explained, the industry doesn’t want unintended consequences to result from the premature elimination of the codes.
Thomas added that as the original ITEM Coalition coverage request didn’t include seat elevation on Group 2 power chairs, the industry would prefer to keep the codes active while additional research is being done.
He suggested the future of the two codes could be reconsidered in the spring.
Piriano was also asked if she knew of any studies that focused on seat elevation for scooters. She replied that she didn’t know of any studies, but hadn’t looked for any.
In a statement to HME Business following the meeting, the American Association for Homecare (AAHomecare) said, “The comments provided during the public hearing demonstrate stakeholders’ commitment and expertise as well as the product innovation that has brought us to this last step in securing sustainable coverage and payment for power seat elevation.
“The testimonies provided by the CRT industry experts illustrated the importance of CMS revisiting the proposed coding and reimbursement for CRT power seat elevation. We remain hopeful that there will be a favorable outcome which will ensure that the individuals who need it will have access to power seat elevation.”
CMS said it expects to announce a final decision in February 2024, with that decision going into effect April 1, 2024.