Competitive Bidding for Seating and Group 2 Support Surfaces

Since forming in 1987, the National Pressure Ulcer Advisory Panel (NPUAP) has served as the authoritative voice for improved patient outcomes in pressure ulcer prevention and treatment through public policy, education and research. After careful review and deliberation, the NPUAP Public Policy Committee recommends against including pressure redistribution surfaces (mattresses, mattress overlays and seat cushions) as part of the competitive bidding process at this time.

Pressure redistribution surfaces are the mainstay for the prevention of pressure ulcers in at risk individuals. Competitive bidding should reduce expenditures while insuring that beneficiaries have access to the goods and services that they need. To achieve this, products within a category must be similar in function. This requirement is not met in the current code classification structure for skin protection seating and group 2 support surfaces. As a result, we are concerned that bidding these products will reduce or eliminate beneficiaries’ access to the specific goods they need-in the end actually increasing health care costs associated with the treatment of pressure ulcers.

Last September, at a hearing of the Health Sub-committee of the House Energy and Commerce Committee concern regarding competitive bidding of adjustable skin protection seating was raised in both submitted statements and publicly during the hearing. The Independence through Enhancement of Medicare and Medicaid Coalition, a consumer-led coalition including the Paralyzed Veterans of America (PVA) and the Christopher and Dana Reeves Foundation, submitted a written statement specifically requesting that custom (adjustable) seating be exempted. In addition, Congressman Jim Langevin (Rhode Island), the first quadriplegic to serve in the US House of Representatives, has stressed the importance of a “properly fitted, adjustable skin protection seat cushion” to permanent wheelchair users and the risks to beneficiaries’ health and health care expenditures, should these individuals not continue to have access to items which meet their needs.

In 2009 (most recent available data) skin protection seat cushions cost Medicare and Medicare beneficiaries less than $400. Medicare’s total allowed charges for these products was approximately $6 million and Group 2 support surfaces cost $91 million. The total U.S. expenditure for wound care treatment is estimated at $11 billion annually; one wound can cost over $40,000 to heal.

CMS included skin protection cushions and Group 2 support surfaces in round one of competitive bidding. Since many individuals at high risk for skin breakdown already have pressure redistribution surfaces, the negative impact of this decision may not be apparent for some time. Sufficient time should be allowed to obtain adequate data and assess the effect on patient outcomes before expanding this program. We request that you contact Health and Human Services Secretary Sebelius to recommend that skin protection wheelchair seating and group 2 support surfaces be excluded from the second round of DMEPOS Competitive Bidding Program.