Per MIPAA legislation, CMS had to remove Group 3 Complex Power Wheelchairs from Competitive Bidding

Per MIPAA legislation, CMS had to remove Group 3 Complex Power Wheelchairs from Competitive Bidding. Standard Power Mobility, including scooters (POVs) and all Group 1 and 2 Power WCs are still included. But rather than bidding this Power Mobility Group as one category, CMS has created 2 separate bid categories.

Look closely at the Power Wheelchairs in the new ‘Complex Group 2’ category: the total utilization for the wheelchair base codes in the CBAs, as reported by CMS, was 173 chairs. AND this includes a highly suspect reporting of ‘1’ chair per code per CBA or most of the codes; causing doubt that the reported utilization is accurate.

Isn’t the Bid program specifically charged with bidding out items with high utilization and/or high dollar expenditure? Why is CMS bidding a group that AT MOST is about $2 million in allowed charges (and more likely $1.5 million, if we conclude that the chairs with utilization of ‘1’ is more likely “0”; which further reduces to about $1.1 million at the 80% actual reimbursementā€¦)

In addition, by including all the accessory and option codes in both the Standard and Group 2 Complex bid categories, CMS is setting up a situation where there will be at least 4 allowables for many of these codes: the KE allowable when used with a manual WC; the no-KE allowable when used with a non-bid power chair; the new Single Payment amount when used with a Standard Power base code; and the new SPA when used with the Complex Group 2 Power base code. This creates a greatly increased administrative burden on CMS and the DME MACs when establishing fee schedules, assignment and processing of modifiers and claims; as well as a significant increased cost to DME providers and their software vendors to manage these multiple allowables.

Is there a basis to challenge this bid category on the grounds that it does not meet the basic program requirements? Administrative costs will far exceed any potential savingsā€¦

Editor’s Note: CRE encourages readers to respond to questions.

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