Alliance Requests HHS, CMS Allow O&P Telehealth Billing
June 15, 2020
On June 11, the Orthotic and Prosthetic Alliance sent a letter to the US Department of Health and Human Services (HHS) and the Centers for Medicare & Medicaid Services (CMS)
Alex Azar, and CMS Administrator Seema Verma, was signed by all member organizations of the O&P Alliance:
"The COVID-19 pandemic has fundamentally altered the manner in which health care providers and suppliers provide items and services to Medicare beneficiaries. Telehealth has become a valuable mechanism for providing care without the risks associated with face-to-face contact," reads a section of the letter.
"In the case of senior and disabled Medicare beneficiaries who are at increased risk for COVID-19, it is especially important that certified and/or licensed orthotists and prosthetists be able to assess, triage, and provide ongoing orthotic and prosthetic care to individuals who remain safely at home. Under normal circumstances, patients would simply visit their orthotist or prosthetist when they were experiencing problems with fit, comfort, or function of an orthotic brace or prosthetic limb. In a pandemic environment, the patient must weigh the prosthetic or orthotic problem against the risk of potential infection by visiting their orthotist or prosthetist in person," the letter continues.
The authors acknowledge that some aspects of O&P care cannot be done via telehealth, but "given the clinical nature of orthotic and prosthetic services—unlike commodity-based durable medical equipment—it is clear that a number of valuable services can be effectively rendered via telehealth…."
The letter also addresses the "inequitable treatment" of reimbursement for non-repair, clinical services provided to O&P patients as compared to other health care professionals (physical and occupational therapists, physicians, and physician extenders) who may provide O&P devices and are able to submit claims for associated clinical services. "The demand for telehealth services under the COVID-19 public health emergency has highlighted the need to remedy this inequitable treatment," the letter reads.
The Alliance suggested that CMS could authorize appropriately credentialed orthotists and prosthetists to use new Healthcare Common Procedure Coding System (HCPCS) codes to bill for O&P telehealth services.
"Use of these codes—or other codes as determined by CMS—by certified and/or licensed orthotists and prosthetists for certain specifically-defined clinical services not directly associated with the delivery of a prosthesis or orthosis would greatly assist the profession in meeting patient needs while limiting the risk of viral infection," the letter concludes.