The National Association for the Advancement of Orthotics and Prosthetics (NAAOP) has released a webcast in which NAAOP General Counsel Peter Thomas, JD, discusses the separation of O&P from durable medical equipment (DME) in private health plans. A summary of the video content follows:
On February 26, three federal agencies responsible for regulating the Affordable Care Act (ACA) announced a proposal to add a new definition of the term “orthotics and prosthetics” to the Uniform Glossary of Coverage and Medical Terms, separate and distinct from the definition of DME. This had been a goal of NAAOP and the O&P Alliance since 2008, even before passage of the ACA. (Editor’s note: To view the proposed uniform glossary, click here.)
The uniform glossary is a collection of standard definitions of medical and insurance terms that assist individuals in understanding their private health insurance options. The document is written at an elementary level, so as to be understood by the vast majority of the public. Inclusion in the Uniform Glossary does not guarantee coverage of O&P services but it does help consumers understand what constitutes O&P coverage and assists them in comparing and contrasting levels of such coverage across competing health plans. It also formally signals separate treatment from DME in private health plans.
A new definition of orthotics and prosthetics in the Uniform Glossary will stimulate consumers to ask questions about the extent of private plan coverage of O&P care. It can be used to argue that DME caps of one sort or another do not apply to orthotic and prosthetic services, and it may prompt health plans to collect better data on O&P benefits and better define coverage of this important benefit.
Orthotics and Prosthetics Definition
The proposed regulation adopts a version of a definition that NAAOP and the Alliance recommended in numerous comment letters over the past six years, since enactment of the ACA. The new definition of orthotics and prosthetics, as proposed in the Uniform Glossary, is as follows:
Orthotics and Prosthetics: Leg, arm, back, and neck braces, and artificial legs, arms, and eyes, and external breast prostheses incident to mastectomy resulting from breast cancer. These services include: adjustments, repairs, and replacements required because of breakage, wear, loss, or a change in the patient’s physical condition.
Comments to this proposed definition are due on March 28, and NAAOP and the O&P Alliance will strongly support its adoption in the final Uniform Glossary. NAAOP and the Alliance may offer some refinements to the definition, but the proposal to add this separate definition of orthotics and prosthetics is an important victory and should be strongly supported by the entire O&P profession and the larger rehabilitation and disability community. This will have an impact on all private insurance plans, not just ACA plans, and it will also strengthen the policy arguments for further separation of O&P from DME in both the Medicare and Medicaid programs.
The webcast is posted on the NAAOP website and on oandp.com, shared with members via e-mail, and made available through the NAAOP page on Facebook.
