The National Association for the Advancement of Orthotics & Prosthetics released a statement regarding proposed CMS changes to coding for off-the-shelf orthoses.
CMS has proposed to expand the definition of what it considers to be off-the-shelf (OTS) orthoses to allow “individuals with specialized training” to fit them, as well as make other OTS orthoses eligible for competitive bidding in the future.
“What CMS has done is greatly expand the scope of what it considers to be off-the-shelf orthotics and eventually, if and when it decides to implement competitive bidding of off-the-shelf orthotics, we expect this to be a much more significant financial impact to the field than it would have been had CMS implemented the letter of the federal law,” Peter W. Thomas, JD, general counsel for the NAAOP, said in a video statement. “We oppose that interpretation that CMS has promligated.”
Representatives from the NAAOP, along with Orthotic and Prosthetic Alliance organizations, recently met with CMS to present arguments that opposed these actions.
“Ultimately, we learned just recently that advocacy had largely fallen on deaf ears. CMS is moving forward with its proposal.” Thomas said. “They have created 23 off-the-shelf codes for orthoses that are currently prescribed under the HCPCS coding system and …about 32 codes that are often now currently provided as off-the-shelf or orthoses that require greater clinical skill, will now only be able to be provided by certified orthotists. The new guidance also suggests that not only can certified orthotists provide them but also individuals with specialized training necessary to custom fit an orthosis. It’s not clear what this actually means.”
Unsure of when the competitive bidding for OTS orthoses will begin and when CMS will assign reimbursement values to the new OTS codes that it has created, the NAAOP is working to address the issues before they occur. Thomas said potential pricing for reimbursement levels for the new OTS codes could lead to dramatic discounting in reimbursement for existing codes.
“It’s disturbing news,” Thomas said. “It may very well have implications on various delivery models that are currently in place and exist with respect to the orthotic field and it’s something that NAAOP and the alliance organizations are working very diligently to try to correct.”