After participating in the Public Comment Meeting held in Maryland
Wednesday I saw what I and others consider to be a day that made O&P
history. This was a grass roots effort from the Amputee and O&P Community.
Seeing the reaction of CGS/CMS top representatives we could all see that we
are in a great position at the moment. We have a chance that we probably
won’t have for a long time to change O&P coverage policy to improve care
for our patients. However, our plight is much deeper than the proposed LCD!
O&P professionals and amputees have been without a real voice in CMS policy
for decades. I heard these points clearly presented:
1) The LCD is unfounded, unreasonable, and “not worth the paper it’s
written on”
2) O&P does not belong with DME
3) The Prosthetist is not viewed as a non-physician LCMP
4) CMS coverage criteria remains vague and subject to interpretation
5) CMS has offered no repeatable criteria for defining K level
6) Prosthetist’s documentation is not regarded
We all know the LCD is deplorable but how was it authored in the first
place? Why were our national organizations not allowed to have say? In
fact, did they even know about it in the fist place? Each and every one of
the speakers should be thanked for their moving
speeches which clearly indicated the serious shortcomings of the LCD along
with its unfounded authorship and profoundly negative impact and unfounded
authorship. I only heard one one concise presentation of a proposed
solution. It was made by Jeff Arnette, CPO, LPO, Member of Region C
Provider Outreach & Education Orthotic & Prosthetics Advisory Group
We humbly submit the following proposal. We 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We suggest that the draft LCD be rescinded, and code changes be delayed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.
2.
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.
3.
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.
4.
We suggest that quantifiable and repeatable clinical measures be
approved for assessing the amputees K level and function. We feel that
the
Amputee Mobility predictor (AMP PRO and AMPnoPRO are the most applicable
to the amputee.
I would encourage those who agree with this framework to forward this and
other proposed solutions to CMS authorities and our leading organizations.
For
information on how you can submit comments before August 31st, visit:
NAAOP’s
website at
www.SaveProsthetics.org
Contact: David McGill
631.627.1603
*Read the full statement below:*
Attn: Dr. Stacey Brennan
RE: Proposed LCD DL33787
Dear CMS Directors,
In regards to recent proposed changes in the CMS coverage of orthotics and
prosthetics, Orthotists and Prosthetists have come together to unite with
one voice for maintained coverage to CMS beneficiaries and reduction in
overall cost of prosthetic care. We understand CMS Goals in cost
containment, consolidation, and uniformity of care and want ultimately to
reach these same goals in a way that is beneficial to the patient and
fosters the development of new technologies to improve the health and
lifestyle of every disabled American.
We have outlined three problematic areas of concern with the current LCD
and the process that authored the proposed changes:
1) Proposed changes did not involve a panel of Certified or Licensed
Orthotists/Prosthetists:
CMS proposed changes and RAC audits have been carried out without peer
review or proper understanding of the history of the services which are
represented by the current coding system. We feel the lack of peer review
in these changes is not in accordance with CMS policies and guidelines.
2) Repeatable Outcome Measures are not present to define K level or medical
necessity:
CMS has offered no repeatable measure for LCMP’s to use to document a
patient’s K level. It has essentially been left up to subjective
observation. In order to deem that services are or are not medically
necessary CMS must offer a measurement of physical ability that is
scientific and repeatable by the patient’s therapist, physician, or
prosthetist/orthotist.
3) Misunderstanding of Outdated Coding:
We understand that CMS must cut unnecessary costs and that the current
coding structure needs review. However, the current proposed LCD is
insufficient in the provision of care that would be provided for patients.
AOPA has laid out these concerns in the Executive Summary and summarized
the negative impact to beneficiaries in detail:
http://www.aopanet.org/wp-content/uploads/2015/07/Proposed-Lower-Limb-Prosthesis-LCD-Summary-and-AOPA-Executive-Summary-for-Distribution-to-AOPA-Members.pdf
Proposal:
We humbly submit the following scenario as a solution:
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.
2.
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.
3.
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.
We recommend that a CMS Advisory board be formed from the membership of the
already established POE group for DME MAC Region C, as the membership is
approved and consists of an optimal cross-section of clinicians, industry
VIP’s, and amputee advocates. We recommend CMS approve the Advisory Board
to be a permanent voice to CMS
practices and that the board have the following responsibilities to present
a solution for Medicare coding structure now and in the future:
– Provide a proposal within a reasonable time frame for CMS to approve.
We suggest 6-12 months.
– Achieve projected reductions in CMS prosthetic spending by a set
percentage
per capita
– Establish set quantifiable measures for defining K level (we recommend the
AMP-Pro)
– Advocate for the patient
– Consolidate Prosthetic coding structures
– Establish updated base coding for each K level to include
reimbursement of socket and component add on codes
Sincerely,
Jeffrey Arnette, CPO, LPO, Member of Region C Provider Outreach &
Education Orthotic & Prosthetics Advisory Group
LPO
Brandon Arnette, BOCPO, LPO
—
Michael Arnette BOCPO, LPO
Progressive Orthotic and Prosthetic Services
www.progressiveoandp.com
9511 E. 46th St.
Tulsa OK, 74145
(918) 663 7077
(918) 724 6256
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