CMS has amended a recent coding clarification regarding custom-fabricated diabetic shoe inserts, which the American Orthotic and Prosthetic Association and the American Podiatric Medical Association had previously criticized as overly strict and a detriment to advanced technology.
According to the original clarification, to bill Medicare for a custom-fabricated diabetic insert using HCPCS code A5513, practitioners would have had to create a physical model of the patient’s foot and then use that mold to fabricate the insert. Any process that used virtual models to create inserts, either through direct milling or other means, would not have met the standard and instead would have had to be billed using the code A9270, which describes statutorily non-covered services.
However, following a joint letter in October from AOPA and the American Podiatric Medical Association (APMA) expressing concern about the clarification, CMS has proposed a change that would allow for the creation of a digital positive model of the patient’s foot using computer-aided design and computer-aided manufacturing (CAD/CAM) technology. Practitioners can then use that model to direct mill a custom-fabricated insert and still meet the A5513 standard, according to an AOPA press release.
“AOPA is pleased to announce that [CMS] has proposed a change to the [Durable Medical Equipment, Prosthetics, Orthotics and Supplies] DMEPOS Quality Standards that addresses AOPA’s concern regarding the recent DME MAC/ [Pricing Data Analysis and Coding] PDAC interpretation of the term ‘molded to patient model’ when used to describe custom-fabricated diabetic shoe inserts,” according to the release.
In addition to the APMA, the AOPA also worked closely with the O&P Alliance, the office of U.S. Rep. Brad Wenstrup (R-Ohio) and the House Veterans Affairs Subcommittee on Health in addressing their concerns, according to the release.
CMS will host an “Open Door Forum” conference call at 2 p.m. Eastern Standard Time on Nov. 28 for experts, including AOPA officials, to discuss the proposed changes to DMEPOS Quality Standards. Public comments on the changes will be accepted through Dec. 11. Comments can be sent to firstname.lastname@example.org.
According to AOPA, CMS has indicated that it intends to finalize the proposed changes by Jan. 1, 2018.
The proposed changes can be reviewed here: www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance-Programs/ReducingProviderBurden.html.