NAAOP Webcast: VA’s Flawed Report Unfavorable to O&P

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The National Association for the Advancement of Orthotics and Prosthetics (NAAOP) has released its latest webcast in which General Counsel Peter Thomas, JD, comments on the release of a report by the Department of Veterans Affairs (VA): Use of Not Otherwise Classified Codes for Prosthetic Limb Components.

Thomas called the findings and recommendations in the report "disturbing." He said, unfortunately, the report reflects a lack of understanding of coding and pricing of new prosthetic technologies. The report was triggered by two anonymous employees who challenged the process for assigning reimbursement levels for new technologies under the prosthetic benefit, Thomas said in the webcast.

The report concludes that the VA overpaid "contract" prosthetists by $7.7 million between 2014 and 2017 because the VA permitted these prosthetists to use "not otherwise classified" or "NOC" HCPCS codes when submitting invoices for new prosthetic technologies to the VA for reimbursement. The report goes on to allege that this allowed the VA, particularly specific individuals within the VA, to overpay contract prosthetists for prosthetic technologies that the Centers for Medicare & Medicaid Services (CMS) reimburses at much lower levels. The report also asserts a lack of sufficient processes, internal approvals, and appropriate oversight for the assignment of these codes and reimbursement values.

"It's a flawed report that does not reflect well on the prosthetic field," Thomas said.

Thomas called the report inaccurate in that veterans who need new technologies would not have been able to access these innovative components if the VA reimbursed at levels established under existing HCPCS codes. In addition, prosthetists would not have provided them to veterans because prosthetists would have taken significant losses by doing so. The new technologies at issue would have been downgraded to more established, HCPCS-coded components instead. It is disingenuous for the VA to routinely tout to Congress and the public how it is at the cutting edge of providing advanced prosthetic technology to veterans and then refuse to compensate prosthetists appropriately to design, fit, and fabricate those technologies into a functional limb, Thomas said.

NAAOP will continue discussing this report with its O&P Alliance partners and expects to respond to the VA as well as the House and Senate VA committees soon. Despite this most recent VA report, NAAOP hopes to work with the VA to ensure continued access to new prosthetic and orthotic technologies in the future, Thomas said.

The latest webcast is posted on the NAAOP website and on NAAOP's YouTube channel as well as on It was also shared with members via email.