The American Academy of Orthotists and Prosthetists (the Academy) issued a formal letter of response to the Centers for Medicare & Medicaid Services (CMS) on the joint publication on Upper Limb Prostheses – Correct Coding. The Durable Medical Equipment Medicare Administrative Contractors (DME MACs) and the Pricing, Data Analysis and Coding (PDAC) contractor produced the publication.
The Academy’s Public Policy Committee urged CMS to recall the implementation and enforcement of current or past claims for upper-limb prostheses based on the newly issued guidance until verifiably correct coding protocols are identified.
In the letter, the Academy expressed concerns related to the following actions and content areas:
- The DME MACs and the PDAC circumvented the required notice-and-comment rulemaking process by not presenting advanced notice and allowing for public comment.
- This newly revised interpretation of the upper-limb prostheses code set has many errors and inconsistencies which need to be corrected and/or addressed.
- There is an increased chance of a diminished level of care for Medicare beneficiaries with upper-limb loss, as well as non-Medicare patients whose insurance companies may base their coverage determinations upon Medicare standards.
- Technical advancements made in recent years for upper limb amputations have neither been recognized nor assigned appropriate coding and pricing to make such technologies available to patients.
To read the letter of response, visit the Academy’s website.