AOPA responds to CMS’ documentation template for lower limb prostheses

The American Orthotic and Prosthetic Association (AOPA) issued a letter to Marilyn Tavenner, CMS, administrator, in response to CMS’s proposed electronic template for medical documentation of lower limb prostheses.

The letter addresses the issues with the proposed template, including the inability for prosthetists to complete the template despite Tavenner’s claim during a May 8 meeting that they will be able to do so. AOPA also expressed concern about the specificity of the form that may discourage physicians from completing it.

“I must report that this template, far from being a step forward, is instead a clear example of a severe lack of understanding of how prosthetic care is delivered to Medicare beneficiaries and is likely to compound the problem we seek to solve,” Tom Fise, JD, executive director of AOPA, stated in the letter.

Fise also addressed the seeming lack of understanding that O&P devices are not durable medical equipment, and emphasized that prosthetic devices are a medical necessity.

“I fear that we can never make any progress toward solving the present problem so long as agency personnel want to re-tread purported solutions for power wheelchair over-utilization to the completely different and unrelated world of artificial limbs,” Fise wrote.

The letter concludes with excerpts from correspondence between AOPA and George Mills, the director of the CMS provider compliance group. In the letter, AOPA highlighted the issues with CMS contractors “using physician records to try to rebut, overturn and invalidate from afar and without ever having examined or having had any other contact with the patient, the professional decision and prognosis of that patient’s physician.” According to Fise, Mills’ response ignored the problem.

Fise closed the letter by asserting that “this document is incompatible both with the kind of possible partial solution you outlined in our meeting on May 8 and with finding a pathway to better care for Medicare amputees and fair treatment of the prosthetic and orthotic health professionals who provide that care.”

To read the entire letter, click here

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