Here it is from another source. Everyone is worried about everyone except Orthotists! They see this as a negative!
Carey Jinright, LO, MSM
“I Am Second”
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Begin forwarded message:
> From: “Jim Hewlett, BOCO, BOC Board Chairman”
> Date: August 22, 2014 at 9:07:06 AM CDT
> To: [email protected]
> Subject: Please comment on the CMS proposed rule by September 2
> Reply-To: [email protected]
>
>
>
> To All BOC Constituents:
>
> We are reaching out today about a matter of critical importance to O&P, you, your business, and ultimately the patients we serve.
>
> CMS has issued a proposed rule that will dramatically limit the care that can be provided by Certified Orthotic Fitters (COFs). The proposed rule, “CMS-1614-P: Medicare Program; End-Stage Renal Disease Prospective Payment System, Quality Incentive Program, and Durable Medical Equipment, Prosthetics, Orthotics, and Supplies,†can be read in its entirety at this link. In Section VIII on page 40297 (pdf page 91) you will see that in the current proposed rule COFs are essentially cut off from providing care to Medicare patients.
>
> Clearly, there is grave concern with this proposed rule, and BOC will be submitting comments to CMS about a number of them, both from BOC alone and along with the other major O&P organizations in a joint comment from the O&P Alliance*. Particularly alarming is that the rules state that Orthotics: custom-fitted prefabricated (OR02) may be dispensed and billed only by “individuals with specialized training,†which the rule defines as Orthotists, Physical Therapists, Occupational Therapists, Advanced-Practice Nurses, and Physicians. COFs are not included in this list. One way to address this omission is to point out to CMS that it has already given the authority to establish the requirements for provision of prefabricated orthoses (OR02) to its deemed accreditation organizations (including BOC).
>
> We urge you to submit a comment to CMS by September 2, and strongly oppose this aspect of proposed rule CMS-1614-P. You can send your own comment to:
>
> Marilyn Tavenner, Administrator
> Centers for Medicare and Medicaid Services
> U.S. Department of Health and Human Services
> Attention: CMS-1614-P
> P.O. Box 8010
> Baltimore, MD 21244-8010
>
> Or click here for a pre-written message that you can easily customize and submit. The text that appears in red should be deleted and replaced with your own words. Feel free to personalize or modify any other sections, as well. Then, submit your comment online at this link.
>
> Thank you in advance for taking action. If you have any questions or if we may be of additional assistance, please email [email protected].
>
> Sincerely,
>
> James L. Hewlett, BOCO
> BOC Board Chair Claudia Zacharias, MBA, CAE
> President & CEO
>
> P.S. We encourage you to forward this email to your colleagues and others who also should comment, as we need to make sure CMS hears our message loud and clear. Remember, the deadline to comment is September 2.
>
>
>
> *The Alliance’s input to CMS, which includes many additional comments that are not outlined here, may be found at this link.
>
>
> Board of Certification/Accreditation | 10451 Mill Run Circle, Suite 200 | Owings Mills, MD 21117
> 877.776.2200 | 410.581.6222 | BOC Website
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