Fellow colleagues:
We returned this week from a powerful day in Maryland. I was able to present at the meeting, and was proud to be part of the throng of those who came to fight for the success story of amputee care in America. We are grateful to our colleagues, to those on the receiving end of care, and to those in O & P organizations who have worked very hard facilitating
We have a few observations, and some perspective. In the main, we need to use this momentum. This LCD is part of a long line of unsolved problems between Medicare and the O & P industry, and is likely not the last. We need a long term solution, one that helps to work out the current issues and preempts further disasters.
We have heard individuals, independent thinkers, and officials within Medicare state that O&P should be separated from DME.
We also need a voice within Medicare. We advise you to petition CMS for and advisory board within Medicare, as we feel many of these problems could have been avoided slimply by having amputees, prosthetists and industry leaders party to internal CMS discussions.
We encourage you to comment before the period ends, and to consider the above points. You can read what we have submitted to CMS below.
request that you read our full proposal after this summary:
1. We suggest that the draft LCD be rescinded, and code changes be delayed in order to allow Industry leaders, Amputee Advocates, and Prosthetic professionals to participate in a workable solution to reduce cost without negative impact to patient care.
1. We suggest that an advisory board of prosthetic clinicians and industry representatives be established to provide advice to CMS on consolidating coding, and coverage determination. Region C has already established a board of qualified, approved industry leaders, clinicians, and amputee advocates.
1. We suggest that CMS permanently and finally separate Orthotic and Prosthetic devices and their respective L-codes from DME MAC. O&P care (with a very few exceptions) requires a highly trained professional to select and provide the necessary care to the patient. Orthotists and Prosthetists should be recognized as the LCMP that they are. Competitive bidding DME items should be placed under a separate coding structure, as these items require limited training or experience.
Sincerely,
Jeff Arnette, CPO, LPO
Member of Region C Provider Outreach & Education Orthotic & Prosthetics Advisory Group
Progressive Prosthetics www.progressivepo.com
