The proposed LCD changes do not just impact people getting prosthetic
services – it impacts anyone who needs a custom orthosis as well, and
potentially every American who might someday need P&O care as they age.
Has anyone tried to get this story to the Media? It seems like a
compelling story of a small profession and the Americans with
disabilities that they serve being squashed by Big Government. I
wonder, where are the manufacturers on this issue? Where is the VA?
Where are retired Veterans who wear prostheses? Are the P&O university
programs and their students getting involved? What about the large P&O
Corporations; are they and their staff and patients trying to stop this?
(If I owned stock in a publicly traded P&O Corporation, I would be very
worried because they too, along with their clients with disabilities may
take a big hit if this goes through…) We’re likely to see large
lay-offs and consolidation of branch offices, particularly in rural
practices result from this…. From the small company to the large, from
rural America to Urban centers, for patients regardless of where they
get their P&O care, this will potentially send our long-term care back
into the relative dark ages…. I have seen the petition to change,
delay or overturn the proposed LCD changes sent from AAOP, AOPA, ABC,
BOC, NAAOP, the Amputee Coalition and others. But I have seen only one
request for signatures and/or action by Otto Bock. Kudos to them…
Hopefully other manufacturers, suppliers and those in P&O R&D will
follow. It may seem as if the manufacturers have a “profit motive” by
getting involved and passing this information on to clients. Downstream,
however, it is Americans with disabilities who need P&O care who will
suffer, have reduced access to care and technologically-outdated
prostheses at that. If these LCD changes are enacted, there will be many
components that will no longer be covered for the average amputee, so
the market for them in the US will mostly die out. US manufacturers of
components and materials along with small private practices are likely
to take a huge financial hit, forcing many out of business altogether
unless they’re established in Canada, Europe, the UK, etc. Small
practices in rural areas are likely to take the first and hardest hit if
they aren’t already out of business due to the oppressive and unfair RAC
audits (which let’s face it, are just a money-making racket for the
Contractors who could care less about people with disabilities who need
P&O care). Ironically, even the RAC auditors would suffer because the
Prosthetics profession will shrink, meaning fewer practices to audit and
from which to squeeze the life from. Consider that incentives for R &
D into improved and advanced technology will likely die on the vine in
the US. Sure, some companies are developing techniques and components
for wounded warriors from Government grants, but most of those
developments will only survive if they can be utilized by the much
larger civilian population (and eventually wounded warriors would likely
be getting the same technology that made it to mass-market when they
retire). The proposed LCD changes potentially negate 7 decades of
advancement in Prosthetic care, much of it a direct result of R&D that
was funded federally for the express purpose of improving the lives of
our wounded veterans. Some advancements have also been by entrepreneurs
who had great ideas, developed them and built businesses on advanced
techniques and technology. Will they survive this if CMS has killed the
market and incentive for innovative and advanced P&O technology? Now,
CMS intends to turn its back on those who have bled and died for our
country, by pushing prosthetic care for civilians and veterans alike to
pre-WWII standards of care. The US, which has led the world in
advancement of prosthetic care in many ways, will be the laughing stock
of providers of P&O services in Canada, Europe, the UK, and many urban
centers even in developing nations. If these changes are enacted, it
may soon make more sense to leave the US and travel to Mexico City for
example to get decent prosthetic care. In many ways, thermoplastic
prostheses using the ICRC technology that was implemented after the
earthquake in Haiti as emergency relief care, will be of higher quality
than the basic device that CMS says Americans with Disabilities can
receive.
Finally, this concept that someone who gets a crutch, cane, or walker
paid for by Medicare is not eligible for components that are advanced or
for active amputees is ridiculously short-sighted. I’m a 56 year old
double Trans Tibial amputee who also had major unrelated surgery last
year. Within a span of four months, I needed a walker, then I used my
crutches and a single crutch briefly before returning to work full time.
With my prostheses with dynamic response, multi-axial feet, I walk on
uneven terrain, climb stairs, can jog, snow-ski, and am very active and
productive. I did not need new prostheses after this surgery, and I am
not currently on Medicare. But since Insurance follows CMS guidelines
often, this could easily be the situation for anyone needing a
prosthesis. Had I been on Medicare and needed a new pair of legs, CMS
would have said, “Oops, too bad, no dynamic or multiaxial foot nor
elevated vacuum sockets for you…! We bought you a walker, thus you are
relegated to K-2 components.” I once met with a double amputee who at 81
had only just lost both legs to Meningococcemia. He was successfully
fitted with temporary and intermediate prostheses, using a walker at
first, that enabled him to regain his health and vitality instead of
languishing in bed or being told he could only get a wheelchair. After
rehab, he returned on his definitive prostheses to an active lifestyle
including golfing several times a week. He was not dependent on the
system, he continued to be productive, pay taxes and contribute to his
community and to be a grandfather and great grandfather for another
decade. Today, if CMS enacts these changes, I think he would be far
less likely to make it out of the wheelchair at all. Is that really how
the US, via CMS’s regressive policies, is going to reward its retired
citizens who’ve paid into the system all their lives?
Don Cummings, CP (LP) FAAOP
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