This is forwarded from another list. I hope you don't mind.  But,
considering how many wheelchair users there are out on the web....

Beth the OT

-----Original Message-----
From: Mark Schmeler, M.S., OTR/L, ATP [mailto:[log in to unmask]]
Sent: Thursday, March 09, 2000 6:49 PM
To: Technology SIS Listserv
Subject: [tech-sis] URGENT! HCFA!


I suggest those of you involved in seating and mobility respond with
comments to HCFA before 3/17.  This could devastate how we provide services
to Medicare beneficiaries.  If implemented, it means there would only be one
type of wheelchair and one type of cushion (lowest bid) available.  Mark

FUNDING EMERGENCY - YOU NEED TO BE AWARE AND ACT!!!!!!!!!!!!!!!!
Deadline is March 17, 2000
In January HCFA published the list of products to be included in the second
competitive bidding demonstration project. Included in this list were:
Oxygen equipment and supplies;
Hospital beds;
Standardized orthotic products;
Manual wheelchairs; and
Nebulizer drugs.
Basically, competitive bidding could dramatically limit your flexibility in
product selection. Be aware this effects manual wheelchairs, wheelchair
accessories, and cushions.
These product were published in the Federal Register on January 7th when
HCFA requested emergency clearance from OMB to implement the second phase
of competitive bidding.
Today we became aware that HCFA expanded the list of products it intends to
include and published the list of codes it
proposes on approx. 2/14. In this expanded list HCFA broadened "manual
wheelchairs" to be "manual wheelchairs and
accessories". As a result, E0192 has been included in the list of products
to consider for competitive bidding. Furthermore, they are requesting any
comments be submitted by February 29, 2000 (note this has been extended to
approx. March 17th) to:
Medicare, AG-400
DMEPOS Competitive Bidding
Palmetto GBA
P.O. Box 100164
Columbia, SC 29202-3164
Fax (803) 935-0078
You can access further details by going to www.hcfa.gov/ord/dme2hcpc.htm
There are concerns about E0192 being included in a competitive bid at this
time. The primary concerns are as follows:
"Wheelchair accessories" were not included in the original list published in
the Federal Register. As such, interested parties felt no need to submit
comments. How can HCFA expand the list without republishing in the Federal
Register and allowing for a reasonable comment period by
interested parties? Based on the current structure of code E0192 a variety
of products are included which are designed to address a variety of patient
needs / conditions. Currently products would be included that address:
- positioning only,
- wound care, and
- a combination of wound care and positioning.
The cost structures associated with the various product groups included in
this one code vary widely. How can such a code be
competitively bid and still address the variety of patient needs, product
types and cost structures?

Currently E0192, as well as seat cushion codes in general, are in review
with the SADMERC and the DMERCs. There is an ongoing effort
by representatives of these HCFA contractors as well and representatives of
various clinical elements and industry to redefine existing seat
cushion codes and develop an overall medical policy for such devices. Any
code which is in the midst of such a review is not a good
candidate for inclusion in competitive bidding as their entire structure
(i.e. product definition, coverage criteria, approved products, etc.)
may change before the next competitive bidding project starts (or during
it). Clearly, you cannot submit a bid for a specific HCPCS code
only to have the logic behind the code change.
This is very short notice, however if you agree with these comments /
concerns it is important you take whatever action you deem appropriate.
If you have any questions or need more clarification, please contact Ann
Eubank, OTR, ATP (800) 851-3449 x2004, [log in to unmask]

********************************************
Mark R. Schmeler, M.S., OTR/L, ATP
Director of Clinical Services, Center for Assistive Technology
UPMC Health System
Instructor,  Dept. of Rehab. Sciences & Technology
University of Pittsburgh
AddressEtc.
Forbes Tower, Suite 3010
200 Lothrop Street
Pittsburgh, PA 15213-2582
(412) 647-1313 Fax (412) 647-1322
email: [log in to unmask]
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