NAAOP announces next steps in fighting LCD proposal

O&P practitioners were encouraged to attend a public comment meeting and to submit written comments as next steps in fighting the recently published draft policy that, if finalized, will govern Medicare coverage of lower limb prostheses.

In a webinar presented by the National Association for the Advancement of Orthotics and Prosthetics (NAAOP), David McGill, JD, NAAOP president and Peter W. Thomas, JD, NAAOP general counsel, updated members of the O&P community on the steps the organization, along with its partners, has taken since the draft policy for Local Coverage Determination (LCD) for Lower Limb Prosthetics was released by the four Durable Medical Equipment Medicare Administrative Contractors (DME MACs).

“The reaction [to the LCD] has been pervasive and consistent and is really unprecedented,” McGill said. “There are issues that often come up [in the O&P community], but you rarely see the level of unity and strength of response we have seen on the draft LCD.”

For example, he said, the O&P Alliance, a coalition of organizations that includes NAAOP, formed a prosthetic care subgroup that drafted a comprehensive response to the LCD.

“The work has literally been done on a line-by-line basis through the entire 40-page document,” McGill said.

In addition, Hanger Clinic has developed a series of white papers on the LCD with specialists from different parts of the organization providing input on specific sections.

Meanwhile, NAAOP created the website and spearheaded a “We the People” petition that garnered more than 100,000 signatures in 17 days, according to McGill.

“The White House actually, to the best of our knowledge, has never had a disability-related petition in the ‘We the People’ online process exceed 100,000 signatures, so this really is kind of a watershed moment with respect to that platform as a mechanism for voicing concern about health care policy,” he said. “We are now in a position where the White House is obligated to respond to that, and all indications are this is something they are taking very seriously.”

NAAOP has developed an action plan in response to the LCD, and one of its next steps is for members of the O&P community to attend the public comment meeting that will be held Aug. 26, 2015 in Linthicum, Md. Thomas said so many attendees have already registered for the meeting that it may be moved to a new location to accommodate the crowd. Additionally, he said, there is now a cutoff for the number of registrants who can speak during the meeting.

“If you are going to participate in that meeting, you have to register today,” he said. Online registration for the meeting is available through the National Government Services website.

McGill and Thomas also advised practitioners to submit written statements on the policy to Stacey Brennan, DME MAC Region B Medical Director, which can be sent through the NAAOP website. Comments must be submitted by Aug. 31, 2015.

“We encourage you to sit down … if you have not already done it … and write your own letter, and write something of substance that they can benefit from when those letters are submitted,” Thomas said.

McGill added that letters should focus on the policy and its impact, including constructive suggestions.

Overall, the pair said they are heartened by the support from the O&P community; from groups in other specialties such as rehabilitation and disability; and from the public.

“Perhaps there is a silver lining here of motivating this field to really assert itself and to demand that we are not second class, that we have a patient population that is an American success story in health care, and this LCD is something that slams the brakes on that,” Thomas said. “It is just great to be part of that effort.”— by Amanda Alexander

Reference: McGill D, et al. NAAOP LCD Update: Countdown to Public Comment Meeting. Webinar; Aug. 21, 2015.


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