CMS has proposed a new rule, CMS-6012-P, “Establishment of Special Payment Provisions and Requirements for Qualified Practitioners and Qualified Suppliers of Prosthetics and Custom Fabricated Orthotics,” which removes the exemptions for PTs and OTs to quality standards and orthotic certification, and would require licensure in orthosis fabrication by the state or the American Board for Certification in Orthotics and Prosthetics, or the Board for Orthotist/Prosthetist Certification, or a program “approved by the HHS Secretary” in order for Medicare to reimburse for custom orthotics. Therapists who did not meet the proposed new standards would not receive payment for custom-fabricated orthoses, and may face revocation of both their Medicare and DMEPOS eligibility.
PTPN has submitted comments opposing the rule, and urging CMS to retain the exemption for PTs and OTs. You can too. The comment period is open until March 13. It’s easy to submit a comment of any length, either via the website, or you can upload a PDF. Click here to submit your comment electronically.
If you provide custom orthotics to Medicare patients, opposing this rule is important to your practice. You should convey the experience of your practice, your therapists, and your patients. On the same link, you can also view the hundreds of comments already posted (you’ll find the link below the green “Submit a formal comment button” — close the comment form if you don’t see it) to see what others are saying. Here are the highlights of PTPN’s comments:
The exemption to the accreditation requirement for occupational and physical therapists should be continued.
This rule would negatively impact patient care provided by PTs and OTs that provide custom orthotics. It will severely limit patient access and negatively impact patient outcomes, robbing OTs and PTs of an important tool in patient care for upper and lower extremity rehabilitation.
Medicare patients would be required to travel to an additional practitioner in order to receive their orthotics, then return to rehabilitation, then later return back to another practitioner to have the orthotics adjusted to reflect changes in the patient’s condition, then back to rehab and so on, leading to increased inconvenience and expense for Medicare and the patient.
There is no justification for requiring a licensed therapist to now be placed under the accrediting jurisdiction and discretion of another profession for one aspect of the care they typically provide. Under the proposed rule, PTs and OTs would be required to meet the American Board for Certification of Orthotics, Prosthetics or Pedorthics (ABC) accreditation requirements. To meet those standards, therapists would be required to attain an additional degree in orthotics and prosthetics. In addition, accreditation candidates are required to complete a year-long National Commission on Orthotic and Prosthetic Education (NCOPE) approved residency prior to sitting for the exams. It would be an unreasonable burden to fulfill these requirements while remaining employed.
We urge you to reconsider the requirements of this rule as they apply to occupational and physical therapists proposed in CMS 6012-P. There is no benefit to beneficiaries, and no demonstrated cost savings to the Medicare Program.
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