The National Association for the Advancement of Orthotics and Prosthetics (NAAOP) has released a webcast about policy changes made by the Centers for Medicare & Medicaid Services (CMS) in regard to off-the shelf (OTS) orthotic devices. In November, CMS created 23 new Healthcare Common Procedure Coding System (HCPCS) codes for orthoses that are always provided OTS, based on CMS’ determination. CMS also amended the descriptors for 32 other codes that it found could be provided as OTS devices, or could require clinical care. The changes are effective January 1, 2014.
Because Congress has defined OTS orthoses as devices that require minimal self-adjustment, NAAOP General Counsel Peter Thomas, JD, stated that CMS has expanded the scope of what Congress intended OTS orthotics to include. The significance of the new set of codes, according to Thomas, may stem from CMS looking to competitively bid more aspects of O&P care, as well as the December 2012 Office of Inspector General (OIG) report on L-0631 back orthoses (short code: LSO sag-coro rigid frame pre), which found that many of the suppliers who billed for L-0631 did not provide additional clinical care.
Thomas pointed out that certified orthotists or “individuals with specialized training necessary to custom fit an orthosis” can provide and bill under these new codes, but the definition of specialized training remains unclear, as does the impact of the coding changes.
In the webcast, Thomas said that the policy change was opposed by NAAOP when it was initially proposed, and NAAOP and its allied partners plan to continue efforts to improve the outcome of the policy.
The webcast is posted on the NAAOP website, shared with members via e-mail, and made available through the NAAOP page on Facebook.