It has come to the PDACAC’s attention that there is a manufacturer indicating that a product has been code verified by the PDAC as K0800; however in researching this product we have found that the product name (Phoenix 3 Wheel Scooter) is not listed on the PDAC product classification list and the model number is associated with an entirely different product (Phantom 4 Wheel Scooter) that the manufacturer does not list as available on their website.

The Phoenix 4 is listed on DMECS as K0800 (4-wheel instead of a 3-wheel). In researching their website and DMECS, it appears the product name may have changed from Phantom to Phoenix in 2009, or the Phantom was discontinued and Phoenix took its place. Thank you for bringing this to the PDAC’s attention. Consistent with the information posted on our website page, Discrepancies in Product Review Information, we will contact this manufacturer to have this product re-reviewed.

It has also come to our attention that this same manufacturer has 2 products listed on the PDAC product classification list as being code verified K0801 (the Phoenix 3 HD and the Phoenix 4 HD) that, according to a DME supplier,does not meet the minimum dynamic stability incline requirement of 6 degrees, even at the minimal weight capacity. The supplier has alleged that these products are unsafe and is questioning how the devices ever received coding.

The Phoenix HD3 and Phoenix HD4 were reviewed in 2012. The test report from an independent testing facility shows the scooters as passing all test requirements, including the dynamic stability incline requirement which were tested at 6 degrees at a weight of 350 degrees. Thank you for bringing this to the attention of the PDAC. We will follow-up with the testing facility.

Q1. How often does the PDAC re-review and request a sample of any previously coded product if it determines the product may have changed, or coding guidelines have changed from when the product was initially code verified?

As stated on our website page titled Coding Verification / Assignment of HCPCS Codes, PDAC reserves the right to re-review and request a sample of any previously coded product if it determines the product may have changed, coding guidelines have changed from when the product was initially coded or in the course of a normal systematic review of HCPCS coding decisions. If this re-review determines the current HCPCS code assigned is no longer correct, a new code may be assigned to the product.

In addition, when PDAC confirms a coding verification, manufacturers/distributors are informed in the coding verification letter sent to them that it is their responsibility to notify the PDAC immediately of any changes involving their products as listed on the PCL in DMECS. Needless to say, this is not always done, so we rely on the processes outlined above as well as the diligence of DMEPOS suppliers to notify us when they believe there is a coding discrepancy.

Q2. Would it be an appropriate use of the “contact us” communication tool for DME suppliers to alert the PDAC to issues such as the ones identified above as most suppliers do not know that the PDAC Advisory Committeeexists?

Yes, you can use the “Contact Us” on the PDAC website or call the PDAC Contact Center at 877-735-1326. This process is described on our website page titled Discrepancies in Product Review Information.

Q3. Should a cantilever armrest that adjusts in height for individual patient placement that is then secured to the back frame of the wheelchair with a nut and bolt such that it allows the armrest to be removed for safe transfers by pivoting up and out of the way (flush with the back cane) be coded K0108, E0973 or E0020?

(E0020 is not a valid HCPCS code. We believe you meant K0020.)

This item is a non-detachable or fixed armrest that combines 2 separate functions. It provides (1) height adjustability and (2) the pivot feature moves the armrest in a fashion analogous to a swing away armrest.

There is no additional payment or billable HCPCS code for cantilever flip-up armrests as the function which it provides is included in the Basic Equipment Package for power wheelchairs and /or in the power seating systems sections of the Coding Guidelines. If billed separately, use A9900.

Please refer to the Wheelchair Options/Accessories - Policy Article. The Policy article says:

GENERAL:

Power Wheelchair Basic Equipment Package - Each power wheelchair code is required to include all these items on initial issue (i.e., no separate billing/payment at the time of initial issue, unless otherwise noted). The statement that an item may be separately billed does not necessarily indicate coverage

  • Armrests. There is no separate billing/ payment if fixed, swing away, or detachable non-adjustable height armrests with arm pad are provided (K0015). Detachable, adjustable height armrests (K0017, K0018, K0020) may be billed separately.

POWER SEATING SYSTEMS

A power tilt seating system (E1002) includes: a solid seat platform and a solid back; any frame width and depth; detachable or flip-up fixed height or adjustable height armrests; fixed or swing away detachable leg rests; fixed or flip-up footplates; a motor and related electronics with or without variable speed programmability; a switch control which is independent of the power wheelchair drive control interface; any hardware that is needed to attach the seating system to the wheelchair base. It does not include a headrest. It must have the following features: ability to tilt to greater than or equal to 20 degrees from horizontal; back height of at least 20 inches; ability for the supplier to adjust the seat to back angle; ability to support beneficiary weight of at least 250 pounds.
A power recline seating system (E1003-E1005) includes: a solid seat platform and a solid back; any frame width and depth; detachable or flip-up fixed height or adjustable height armrests; fixed or swing away detachable leg rests; fixed or flip-up footplates; a motor and related electronics with or without variable speed programmability; a switch control which is independent of the power wheelchair drive control interface; any hardware that is needed to attach the seating system to the wheelchair base. It does not include a headrest. It must have the following features: ability to recline to greater than or equal to 150 degrees from horizontal; back height of at least 20 inches; ability to support beneficiary weight of at least 250 pounds.
A power tilt and recline seating system (E1006-E1008) includes: a solid seat platform and a solid back; any frame width and depth; detachable or flip-up fixed height or adjustable height armrests; fixed or swing away detachable leg rests; fixed or flip-up footplates; two motors and related electronics with or without variable speed programmability; a switch control which is independent of the power wheelchair drive control interface; any hardware that is needed to attach the seating system to the wheelchair base. It does not include a headrest. It must have the following features: ability to tilt to greater than or equal to 20 degrees from horizontal; ability to recline to greater than or equal to 150 degrees from horizontal; back height of at least 20 inches; ability to support beneficiary weight of at least 250 pounds.

Q4. If the armrest is secured to the back frame with a quick release pin as opposed to a nut and bolt does it change the code that should be used to describe the device?

A quick release pin as opposed to a nut and bolt does not change the code of the device.

Q5. How does the PDAC keep abreast of product changes and developments to ensure the most accurate HCPCS code and code descriptions are being communicated and applied?

The PDAC works closely with the DME MACs and the Center for Medicare and Medicaid Services (CMS) HCPCS Work Group to ensure accurate HCPCS codes and code descriptors are developed. The PDAC in collaboration with the DME MACs often post Bulletin Articles to our respective websites to communicate correct coding.

The PDAC has a process in place for manufacturers and distributors to set up times to meet with the PDAC and demonstrate new products as described on our website page titled PDAC Meeting Requests. In addition, PDAC staff attends trade shows to keep abreast of product changes and developments.

We are concerned about the accuracy of the "additional search terminology" used to define sealed, lead acid batteries (E.G., Gel cell, Absorbant glassmat coded E2361, E2363, E2365 and E2371) used with power mobility devices. According to the BatteryCouncil International (BCI), "batteries are classified into numbered Group Sizes according to their voltage, maximum overall dimensions, terminal arrangement, and special features that affect battery fit". The reference is one of physical dimensions, not electrical properties. A22NF, Group 24, U-1 or Group 27 battery,by physical dimension, remains constant regardless of temperature, humidity, state-of-charge, rate of discharge, voltage, or any other electrical definition.Since there is a general correlation between the size of the case and ultimately the amps just due to physics, many people improperly use a battery size to refer to a level of amps.

We respectfully request the PDAC remove the “additional search terminology” from HCPCS detail included with the E2361, E2363, E2365 and E2371 HCPCS codes.

Thank you for bringing this to our attention, we have reviewed the additional search terminology and agree this may cause confusion. This will be removed.

Additional Response Received 10.03.13

From: Pat Pollert

Sent: Thursday, October 03, 2013 12:38 PM

To: Roberson, Sheila

Cc: Pat Pollert

Subject: RE: PDACAC Questions

Sheila, I wanted to follow-up on the question regarding the wheelchair testing results. As I stated in the response letter, the test was conducted by an approved independent testing facility and they confirmed that the chairs they tested did fall within the acceptable range. A correction to our response should read The test report from an independent testing facility shows the scooters as passing all test requirements, including the dynamic stability incline requirement which were tested at 6 degrees at a weight of 300 pounds. (not 350 degrees).

PDAC suggests the DME supplier contact the manufacturer to discuss the concerns with the safety of these chairs based on what the supplier has experienced. PDAC cannot require the chair to be re-tested since adequate test results have been confirmed by the testing lab.

Pat Pollert RN, MBA

PDAC Program Director

NORIDIAN HEALTHCARE SOLUTIONS LLC, FARGO