Dear Editors, The current LCD on prosthetic requirements for K3 and K4 components is unmanageable. My ability to control a physician's evaluation of an amputee and assure my evaluation concurs with his, without the use of preprinted forms or guidelines, is essentially impossible. Virtually every physician ordering prosthetics has no idea what is required by CMS to justify a prosthesis, let alone K3 or K4 components. In addition, since we (prosthetic providers) have a financial interest in the patient, our evaluations must be corroborated by the ordering physician or they are considered invalid in the eyes of CMS, even though prosthetists must pass a rigorous certification exam, attain a certain level of education, and maintain continuing education credit minimums. As this debate rages on, I offer the following suggestion to control the conversation and take a proactive approach to its solution. Since CMS has not defined what is the acceptable "clinical documentation to support functional level of a device and to corroborate the prosthetist's records and the evaluation/ assessment documentation for the functional level of the item(s) billed," I propose the following: Assemble a conference of respected prosthetists, physical therapists, orthopods, and others to create a set of forms listing the criteria, minimum standards, and tests an amputee must meet to clinically qualify for K3 or K4 components. Some of these tests or forms may have to be completed by disciplines other than prosthetists. From this conference a minimum ambulation test may be adopted and performed by a physical therapist. A general health assessment form may need to be completed by the amputee's physician that justifies the K-level of the patient (at least there will be a form for the physician to complete that may be accepted by CMS and remove the burden from the prosthetist to obtain corroborating documentation). In conclusion, I believe this meeting would demonstrate to CMS our commitment as a profession to controlling healthcare costs and setting industry standards for utilization of these highly functional and costly components. Sincerely, Anthony J. Cappa, CPO <a href="mailto:acappa@bayorthopedic.com">acappa@bayorthopedic.com</a> <em>Letters to the editors of </em>The O&P EDGE <em>can be sent to <a href="mailto:editor@opedge.com">editor@opedge.com</a></em>
Dear Editors, The current LCD on prosthetic requirements for K3 and K4 components is unmanageable. My ability to control a physician's evaluation of an amputee and assure my evaluation concurs with his, without the use of preprinted forms or guidelines, is essentially impossible. Virtually every physician ordering prosthetics has no idea what is required by CMS to justify a prosthesis, let alone K3 or K4 components. In addition, since we (prosthetic providers) have a financial interest in the patient, our evaluations must be corroborated by the ordering physician or they are considered invalid in the eyes of CMS, even though prosthetists must pass a rigorous certification exam, attain a certain level of education, and maintain continuing education credit minimums. As this debate rages on, I offer the following suggestion to control the conversation and take a proactive approach to its solution. Since CMS has not defined what is the acceptable "clinical documentation to support functional level of a device and to corroborate the prosthetist's records and the evaluation/ assessment documentation for the functional level of the item(s) billed," I propose the following: Assemble a conference of respected prosthetists, physical therapists, orthopods, and others to create a set of forms listing the criteria, minimum standards, and tests an amputee must meet to clinically qualify for K3 or K4 components. Some of these tests or forms may have to be completed by disciplines other than prosthetists. From this conference a minimum ambulation test may be adopted and performed by a physical therapist. A general health assessment form may need to be completed by the amputee's physician that justifies the K-level of the patient (at least there will be a form for the physician to complete that may be accepted by CMS and remove the burden from the prosthetist to obtain corroborating documentation). In conclusion, I believe this meeting would demonstrate to CMS our commitment as a profession to controlling healthcare costs and setting industry standards for utilization of these highly functional and costly components. Sincerely, Anthony J. Cappa, CPO <a href="mailto:acappa@bayorthopedic.com">acappa@bayorthopedic.com</a> <em>Letters to the editors of </em>The O&P EDGE <em>can be sent to <a href="mailto:editor@opedge.com">editor@opedge.com</a></em>