Medicare documentation requirements for power wheelchairs must be improved, federal report

Inspector General Report Supports Provider and Physician Call for Greater Regulatory Clarity, Consistency, and Improved Education on Documentation Requirements and Process

A federal report released last week on Medicare claims for power wheelchairs confirms that the regulatory documentation requirements are confusing, onerous, and must be improved, says the American Association for Homecare, the nation's largest association representing providers of durable medical equipment and services, including wheelchairs.

The December 2009 report released by the Health and Human Services Office of Inspector General (OIG) found that "three out of five claims for standard and complex rehabilitation power wheelchairs did not meet Medicare documentation requirements during the first half of 2007." These findings are consistent with the experience of power wheelchair providers. They illustrate the fundamental problems that occur when confusing and contradictory policies are applied to the claims process and when standardized Medicare documents approved by the federal Office of Management and Budget are not used.

"The OIG study does not illustrate a problem with provider compliance but rather it reflects the obstacles providers face with Medicare documentation and its paperwork requirements," stated Tyler J. Wilson, President of the American Association for Homecare. "The paperwork requirements are confusing, shifting, and inconsistent."

"The OIG report actually confirms what wheelchair providers and physicians have said for the past three years: the Medicare documentation requirements for power wheelchairs are inconsistent, far too complex, and must be improved so both physicians and wheelchair providers can serve patients and successfully meet Medicare regulations. We obviously want to ensure 100 percent compliance. But the inequity and inefficiencies of this system are evident when, as the OIG found, only 7 percent of claims for complex rehabilitation wheelchairs meet Medicare's documentation standards."

In order for home medical equipment providers to be reimbursed by Medicare, a claim for a power wheelchair requires numerous types of documentation, including a seven-element prescription from a physician, supporting documentation from the patient's medical record supplied by the physician, an onsite home assessment report, a detailed product description, and a specialty evaluation (for complex rehabilitation power wheelchairs).

The American Association for Homecare also notes that:

• Power wheelchair providers, patients and physicians have struggled for years to meet overly complex regulations and requirements in order to provide the medically required equipment to Medicare beneficiaries.
• The home medical equipment sector has repeatedly pointed out the disconnect between physicians' practices and Centers for Medicare and Medicaid Services (CMS) claims requirements.
• Physician organizations have met with CMS to appeal for more appropriate standards that are conducive to the practices of physicians.
• Members of Congress have requested that CMS address the complexities of the Medicare documentation requirements for appropriate and timely claims adjudication.
• Power wheelchair providers have appealed to CMS for years to improve the efficiency and consistency of the claims adjudication process by developing a simple, consistent, and accessible process by which standardized paperwork is reviewed.

"It is important to note that during most of 2006 and early 2007, the time leading up to and including the period covered by the OIG study, there were numerous and often contradictory changes in coding, documentation requirements, and compliance standards," said Tyler Wilson. "These have contributed to the confusion among physicians and equipment providers regarding paperwork expectations. We have been working with both Congress and CMS to improve the documentation requirements and claims-review process to ensure that the Medicare program is paying appropriately for the equipment that beneficiaries need to remain safe and independent in their homes and communities. Congress and CMS should examine the flaws and regulatory burdens of the Medicare claims process. CMS must develop better, simpler guidelines to address the problems, and the American Association for Homecare will continue to work with OIG and CMS to improve the compliance and paperwork process."

In addition to the documentation problems, it is worth noting that Congress has reduced reimbursement rates for power wheelchairs by more than 35 percent over the past five years. These cuts include the following: inflation updates for power wheelchair payments were eliminated from 2004 to 2009; a 9.5 percent cut to reimbursement was included in the 2008 Medicare Improvements for Patients and Providers Act of 2008; reimbursements fell an average of 27 percent as a result of Medicare coding and fee schedule changes in November 2006; and fee schedule prices were cut by approximately three percent in 2005.