NAAOP issues comments on CMS proposed rule

The National Association for the Advancement of Orthotics and Prosthetics has submitted comments in support of a proposed CMS rule that would specify the requirements and qualifications needed for suppliers of custom-fabricated orthotic devices.

However, while the National Association for the Advancement of Orthotics and Prosthetics (NAAOP) supports the proposed rule, David McGill, JD, president of the organization, said CMS should make some changes before final approval.

“We have a number of suggested recommendations to meet the O&P needs of Medicare beneficiaries and believe that CMS must amend some aspects of the rule to comport with current practice in the health care and rehabilitation continuum,” McGill said in a letter on behalf of NAAOP members to Patrick Conway, acting administrator of CMS. “But we applaud the Centers for Medicare and Medicaid Services (CMS) for finally issuing this proposed rule and strongly urge the agency to consider the comments received and timely publish and implement a final regulation.”

The proposed rule interprets Section 427 of the Benefits Improvement and Protection Act (BIPA) of 2000, which states no payment shall be made by the Medicare program to any practitioner or supplier of custom orthotics or prosthetics who is not qualified to provide an appropriate level of care.

If approved, the new the rule would require any practitioner or supplier that provides custom orthotics or prosthetics be licensed if the state in which they practice has O&P licensure, or they must be trained and educated to provide and manage custom O&P care, and be certified by either the American Board for Certification in Orthotics Prosthetics and Pedorthics, the Board of Certification/Accreditation or an accreditation organization approved by the HHS secretary.

According to McGill, BIPA Section 427 was intended to protect patients from unqualified practitioners and suppliers of custom-fabricated orthoses and prostheses, and to protect the integrity of the Medicare program.

“The proposed rule generally meets these objectives,” McGill said in his letter. “Rather than detailing a separate set of positions and recommendations, however, the NAAOP worked in concert with members of the Orthotic and Prosthetic Alliance (O&P Alliance), a coalition of the five major national O&P organizations, to develop a comprehensive statement on the proposed rule, along with specific recommendations for CMS’s consideration. We are proud to align ourselves with this consensus statement of the O&P provider community and look forward to discussing the substance of this proposed rule in further depth in the future.”


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