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February 21, 2017



AAOS Applauds House for Introducing Legislation to Lift Hospital BanEnerg

CMS Proposes Significant Changes to Medicare Standards for Providers and Suppliers of Prosthetics and Custom-Fabricated Orthotics

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CMS Proposes Significant Changes to Medicare Standards for Providers and Suppliers of Prosthetics and Custom-Fabricated Orthotics 

CMS has issued a proposed rule that would revise the standards for qualifications that providers and suppliers must meet in order to furnish, fabricate, or bill for prosthetics and custom-fabricated orthotics under the Medicare program.  If finalized it would take effect in future months but the agency is still considering whether to move forward with the changes and stakeholders have the opportunity to provide input via public comments.
Under the proposed rule, as a condition of Medicare payment, prosthetics and custom-fabricated orthotics (as defined by CMS) must be:

  • Furnished by a qualified practitioner.  CMS proposes to define a qualified practitioner as an occupational therapist, ocularist, orthotist, pedorthist, physical therapist, physician, or prosthetist who meets specified standards.  In particular, if the practitioner is not an enrolled Medicare DMEPOS supplier, the practitioner must be:  (1) licensed in orthotics, pedorthics or prosthetics, or (2) in states without licensure, specifically trained and educated to provide and manage the provision of pedorthics, prosthetics, and orthotics, and certified by the American Board for Certification in Orthotics, Prosthetics and Pedorthics (ABC), the Board for Orthotist/Prosthetist Certification International, Incorporated (BOC), or an organization with equivalent standards.
  • Billed by a qualified supplier.  CMS proposes to define a qualified supplier as a Medicare DMEPOS supplier that is accredited to furnish prosthetics and custom-fabricated orthotics by a CMS-approved accreditation organization (ABC or BOC, or a program the Secretary determines has standards essentially equivalent to those organizations or that employs or contracts with an individual who is certified by ABC or BOC to make the accreditation decision).  Alternatively, the claim may be submitted by a Medicare beneficiary.
  • Fabricated by a qualified practitioner or qualified supplier at a fabrication facility meeting specific standards.  The proposed, highly detailed fabrication facility requirements would include being located in US or its territories and meeting multiple recordkeeping, quality assurance, staffing, and physical facility standards. 

CMS will accept comments on the proposed rule until March 13, 2017 and AAOS will provide extensive comments to the agency regarding the increased regulatory burden the rule would impose.