DME MACs startled wheelchair suppliers earlier this year with a controversial clarification mandating in-person home assessments for manual wheelchair coverage, even when delivering equipment to patients in the hospital or the supplier’s store.
The MACs recently revised their position, but the change of heart is not retroactive.
Home Assessments Then and Now
On January 18, 2024, the DME MACs issued a joint clarification article that included the following:
“The requirement for a direct, in-person assessment of the home environment remains whether the supplier delivers the wheelchair directly to the beneficiary or if a caregiver picks up the chair from the supplier. The confirmation of the home assessment may not be met by indirect methods such as telephone or virtual conversations with the beneficiary or their caregiver, regardless of where or by whom the wheelchair is delivered. The supplier ultimately remains responsible for the completion and documentation of the home assessment.”
Based on previously existing language in the Manual Wheelchair Bases LCD and Policy Article, suppliers understood that indirect assessments, including those conducted using audio and video messaging apps, satisfied Medicare’s requirements. They rightly feared the conflict between common practice and the January 18 clarification created a significant audit liability.
Fortunately, open dialogue prevailed.
DME MAC medical directors responded favorably to arguments that CMS’s underlying intent does not require suppliers make a physical trip to the home if the assessment requirements can be satisfied by other, indirect means. As a result, the DME MACs retired the problematic clarification article and modified the Policy Article to read as follows:
“For manual wheelchairs, the home assessment may be done directly by visiting the beneficiary’s home or indirectly based upon information provided by the beneficiary or their designee. Regardless of the method used for the home assessment, issues such as the physical layout of the home, surfaces to be traversed, and obstacles to the use of the selected manual wheelchair must be addressed by and documented in the home assessment. Information from the beneficiary’s medical record and the supplier’s records must be available upon request.”
The Revised Policy Article is Not Retroactive
Unfortunately, the revised policy article is not effective until July 1, 2024. MiraVista will continue to press for retroactive application, but until then, we recommend suppliers make sure they have documented in-person evaluations for manual wheelchairs delivered between January 18 and July 1, 2024.
What is and has always been clear is Medicare will not cover equipment that patients cannot use in their homes. Regardless of the methods used, suppliers are ultimately responsible for documenting home assessments that comply with the LCD and Policy Article.
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