NAAOP Webcast: Fellowships Conclude, DMEPOS Proposed Regulation

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The National Association for the Advancement of Orthotics & Prosthetics (NAAOP) has released its latest webcast in which general counsel Peter Thomas, JD, joined by this year's NAAOP fellows, Alicia Carver and Susannah Engdahl, PhD, gives an update on the 2019 fellowship drawing to a close and a proposed rule change by the Centers for Medicare & Medicaid Services (CMS) to the durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) regulations.

Carver and Engdahl finished their fellowship August 2. Carver's principal project involved direct federal advocacy on the soon-to-be-introduced Medicare O&P Patient-Centered Care Act. Carver and Engdahl visited over 35 House and Senate offices to promote the policies in the bill and to seek cosponsors of the legislation, Thomas said. The meetings focused on the three major committees of jurisdiction over the bill, the House Ways and Means Committee, the House Energy and Commerce Committee, and the Senate Finance Committee. The fellows' last meeting was conducted alongside the Orthotic Prosthetic Group of America's lobbying team with the chief health staffer of Senate Finance Committee Chairman Charles Grassley (R-IA). The Capitol Hill meetings were coordinated with the O&P Alliance and with the American Orthotic & Prosthetic Association's efforts in spearheading the bill.

Engdahl's principal project involved the development of a compilation of clinical and economic evidence from academic literature to demonstrate the value of O&P care for use in advocacy materials. Citations to the evidence base are critical in making compelling policy arguments and Engdahl's work will inform NAAOP's policy and future advocacy efforts, Thomas said.

CMS released the proposed rule containing updates to the DMEPOS regulations on July 29. NAAOP "strongly objects to the regulations and most certainly will comment," Thomas said. Comments on the proposed rule are due by September 27. To submit comments electronically visit, and search CMS-1713-P.

The rule includes a number of provisions that impact O&P, he said. The rule again applies DME-centric policies to O&P care, thereby increasing the importance of NAAOP's legislative push to further separate DME from O&P, Thomas said. The most significant proposals involve a new process for calculating payment amounts for new technologies receiving Healthcare Common Procedure Coding System codes (gap-filling), which may create a disincentive for innovators to invest in bringing new O&P technologies to market. The proposed rule also includes a new consolidated list of DMEPOS items eligible for prior authorization. In addition to the 82 L-codes already eligible for prior authorization, CMS will add 144 new L-codes to the Master List, with little justification, Thomas said.

The latest webcast is posted on the NAAOP website and on NAAOP's YouTube channel as well as on