The American Academy of Orthotists and Prosthetists (the Academy) submitted written comments to the Centers for Medicare & Medicaid Services (CMS) regarding the 2026 Home Health Prospective Payment System Proposed Rule.
The Academy urged CMS to withdraw the orthotics and prosthetics provisions of the rule, citing that the proposed annual accreditation requirements and related measures would impose disproportionate burdens on O&P facilities without improving program integrity or patient outcomes.
The comments emphasized the following key points:
- O&P care should be regulated separately from durable medical equipment.
- The longstanding three-year accreditation cycle should be preserved.
- Oversight should be risk-based and evidence-driven.
- Prior authorization opt-out provisions must remain optional and flexible.
Read the Academy’s full response here.
To read the Proposed Rule, visit the Federal Register.
