Reimbursement and documentation for complex rehab can be exactly that—complex—but you can get paid the first time with a bit of diligence.

Rehab has been affected in all areas of reimbursement and documentation. The new rule that becomes effective on April 1, 2008, will again hit rehab. If your company is going to continue to provide Group 2 single power or multiple power option bases—and any group 3 or higher—you must have an assistive technology supplier/assistive technology practitioner (ATS/ATP) on your staff. The ATS/ATP must have direct contact with patients who are being evaluated.

The rule states: A Group 2 single power option or multiple power option PWC [power wheelchair], any Group 3 or Group 4 PWC, or a push rim activated power assist device for a manual wheelchair must be provided by a supplier that employs a RESNA-certified assistive technology supplier (ATS) or assistive technology practitioner (ATP) who specializes in wheelchairs and who has direct, in-person involvement in the wheelchair selection for the patient.

This is supposed to prevent fraud, but this type of equipment is not likely to be fraudulently billed. To comply, we must be specific in what we have in our charts at the time of billing. Use of the KX modifier indicates that information required for payment of this claim is "on file." Does this mean "in your file?" Well, some are interpreting it as meaning the information can be in the physician's or any clinician's documentation—but the clinical documentation must be in your file prior to billing.

There is a reason you use a KX modifier instead of the CMN. The reason is that you, as a provider, are expected to have documentation (clinical records) if a reviewer asks for it. The information must be in a certain order, dated appropriately, and with justification for not only the base, but for each accessory that you are billing.

The "good" order must contain patient information; date of face-to-face diagnosis related to the mobility impairment; length of need; and the physician's signature and date. What exactly is a "face to face?" It means that the patient is seen by the ordering practitioner eyeball to eyeball. It must be done.

The order can have the date of the first patient/ordering practitioner encounter that began the process, or it could have the date that the physician reviewed the evaluation from the PT/OT who completed the detailed clinical evaluation required for the higher-end rehab bases. A PT/OT evaluation does not take the place of a face to face. The ordering practitioner still must establish the need for the mobility base ordered. The physician has 45 days from completion of all paperwork to get documentation to the provider.

The PT/OT completing the evaluation must have no financial relationship with the supplier, and there must be an attestation statement that the supplier (you) writes out, signs, and dates. Neither the therapist nor the physician must review and sign off on this—this is your responsibility.

The physician must not receive any type of supplier-generated form to complete and return to you (the supplier), but must do the face-to-face visit in their normal format. There must be a specific statement that the main reason for the visit was for completion of a mobility evaluation for a power wheelchair or scooter. This is what CMS is expecting reviewers to look for on any type of audit situation. The ordering practitioner may choose to have a PT/OT complete the more in-depth detailed clinical evaluation, but this does not negate the fact that they must have documentation relating to the need for PMD.

Peggy Walker

Once all documentation is received from the physician and you have it date stamped (or equivalent), you will complete your detailed product description with the description of the item, the code, your charge, and Medicare allowable. This is reviewed and signed off by the physician, and you have 120 days from the date of the face-to-face to deliver the chair. Remember this is separate from the "good" order, and is basically the same format as Part C of the old CMN.

That seems like a lot, but if you step back and use common sense—and work with the ordering practitioner—it will be fine. The good thing about all of this action is that it is a step in the right direction for rehab providers who are finally getting the recognition they deserve for all the years of training and caring for specialty needs.

SPECIALTY ACCESSORIES

For reimbursement and coding in the specialty accessory areas (headrests/ positioning devices, etc), one code does not fit all. There are multiple new codes that do make it easier for billing and getting paid the first time around—which has decreased the need for the "junk" (K0108) code.

To find more articles from Peggy Walker of US Rehab and more articles on mobility reimbursement, visit the free archives section. In the archives, you'll find a knowledge database including articles such as: September 2007 The Bread and Butter Modifier In the absence of CMNs, KX modifiers are the coin of the realm. By Peggy Walker, RN March 2007 PMDs: What Do You Need Proper power mobility documentation can be confusing, but one of the keys is making it simple for the ordering practitioner and knowing exactly what you need in case of a postpay audit. By Peggy Walker, RN December 2007 Minimize Risk and Boost Reimbursement Pay attention to the details of CMS' mobility documentation requirements and get paid faster with fewer hassles. By Denise M. Fletcher, JD

In the power category for 2008, there are only a few new codes.

• E2312 is a PWC accessory for hand or chin control interface, mini-proportional remote joystick, proportional, including mounting hardware.
• E2313 applies to a harness for upgrade to expandable controller, including all fasteners, connectors, and mounting hardware (each).
• E2397 is a lithium-based battery (each).
• E2373 stays but with new narrative—hand or chin control interface, compact remote joystick, proportional, including fixed mounting hardware.

Manual wheelchairs have a few new codes as well, but, of course, all of the manual wheelchair codes are being reviewed for later this year.

• E2227 is for gear reduction drive wheel (each).
• E2228 is for a wheel braking system and lock, complete (each).
• E2205 remains with narrative changed to handrim without projections (includes ergonomic or contoured) any type, replacement only (each).
• E2618 (solid seat support base) is a discontinued code with no crosswalk at this time, and there is some confusion with the narrative—but this is already being addressed by SADMERC and should be resolved soon. At present, we have been instructed to use K0108 for the manual wheelchairs, but the power wheelchairs' solid seat insert is included. Again, this is being addressed. We must make sure that we keep up with changes, stay aware of updates, and are proactive in all areas of rehab reimbursement and coverage.

The next big hurdle will be the coding and pricing of the new manual wheelchairs and accessories. We must make sure that when these come out, we look at each and every base and accessory code. We must work together to make sure we can still continue with the highest level of commitment for our end users, and still remain in business.

Peggy Walker, RN, is billing and reimbursement advisor for US Rehab/VGM, Waterloo, Iowa. She can be reached via e-mail: .