Thursday, May 19, 2022

US Politics

Eric Hammerschmidt, CPO

Hopefully by now you know that CMS has posted on its website the draft
proposed revisions to the Quality Standards, which affect all of you. CMS
is accepting comments until March 25 with the stipulation that comments are
limited only to the highlighted (revised) portions of the posted standards.
They have made it clear that they will not accept any comments on the
existing standards as they have already been approved.

I hope that you all will have time to review them and comment, if you feel
the necessity to do so. Below is the link that takes you directly to the
web site.


http://www.cms.hhs.gov/center/dme.asp Once you click the link on the top of
the page, a page pops up entitled, “Document Details.” Under “Views” you
can select either the pdf or html documents. Below that button is once
labeled “Add Comments” for you to submit your comments if you wish.

I’ve been told that CMS has a new address for where to send your comments,
but I am not sure so I would send them to the one posted on their website
AND the one they gave the 10 accrediting organizations (today) just to make
sure they get them. Here they are:

the one on the CMS web site:
[email protected]

the one we just got:
[email protected]

For all of the practitioners that have followed the traditional path
consisting of a college education, training at an NCOPE accredited school,
completion of a residency and sitting for and passing ABC’s board exam, we
feel this is our chance to let CMS how important formal academic training is
to our profession. I have included my response to CMS. Feel free to copy
and paste if you will or respond with your suggestions. Of particular
interest to my organization is page 15 paragraph 3 which states:

Individuals supplying the item set out in this appendix must possess
specialized education, training, and experience in fitting these types of
prostheses and when appropriate, certification and or licensing.

My response:

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We would like to thank you for your insight into offering better care for
patients receiving orthotic and prosthetic care. The proposed standards
will assist our profession as we continue to work under a medically based
model. Of particular interest to my organization is page 15 paragraph 3
which states:

Individuals supplying the item set out in this appendix must possess
specialized education, training, and experience in fitting these types of
prostheses and when appropriate, certification and or licensing.

It is our interpretation that the definition of specialized education,
training and experience should follow that as described by The American
Board of Certification.(The following information was obtained from ABC’s
website) We believe that CMS should follow the criteria below when
finalizing your Quality Standards.

Educational Standards are listed below

The education requirements for ABC practitioner certification are the only
orthotic and prosthetic educational standards recognized by the
Commission on Accreditation of Allied Health
Education Programs (CAAHEP). These Standards and Guidelines for an
Accredited Educational Program for the Orthotist and Prosthetist are the
minimum standards of quality used to accredit programs that prepare
individuals to enter the profession of orthotics and prosthetics.
Accreditation by CAAHEP is in cooperation with the
National Commission on Orthotic and Prosthetic Education (NCOPE) which
accredits the orthotic and prosthetic clinical residency program. The
Standards and Guidelines serve as the basis for education and clinical
residency requirements established by ABC for individuals seeking to pursue
a career as an orthotist or prosthetist. Requirements are listed below:

* A baccalaureate degree in orthotics and prosthetics
-or-

* A baccalaureate degree in any major and an
orthotics or prosthetics certificate from a CAAHEP accredited program -and-

* A 12-month NCOPE
accredited residency program

An NCOPE residency program is defined as follows:

Post-graduate clinical training is an extension of orthotic and prosthetic
education. Residency evaluation and supervision are stressed as part of the
NCOPE accredited residency programs. Residents are
supervised by ABC certified practitioners throughout the process of patient
care, constructive feedback is provided by the supervisor, and clinical
responsibilities are graduated by progressive levels of independence to
enhance judgment, skills and clinical expertise.

The range of residency sites is varied including private practices,
multi-site practices, hospital based practices, university based practices
and rehabilitation facilities. To qualify to be a residency site the
facility must be an ABC accredited facility.

Residency allows the ABC certified practitioner to invest in the
professional development of the next generation of practitioners.

Board examinations taken after completion of the residency include:

ABC’s certification programs provide professional recognition to orthotists
and prosthetists that meet educational and residency requirements and pass
the examinations. The practitioner examinations consist of three separate
exams which measure different knowledge and skills.

The first examination is a multiple choice Written Exam that documents those
candidates possesses a critical core of knowledge related to their field.
General knowledge assessed on the written exam may include anatomy,
kinesiology, material science, and practice management. The written
simulation examination constitutes the second part of the examination
program and measures candidates’ clinical decision-making skills through an
interactive format. The simulations imitate lifelike situations an orthotist
or prosthetist might encounter in daily clinical practice. The third
examination, the Clinical Patient Management (CPM) examination assesses
candidates’ professional role and responsibilities. The CPM requires
candidates to demonstrate to an examiner his or her practical abilities in a
clinical environment. Skills such as patient evaluation, prescription
criteria, measurement techniques, fitting, alignment and appropriate
handling of patients are evaluated.

The development of valid examinations begins with a clear and concise
definition of the knowledge, skills and abilities needed for competent job
performance. The questions on the examination were developed by content
experts using tasks identified in the ABC Practice Analysis of the
Disciplines of Orthotics and Prosthetics. The Practice Analysis outlines
contemporary orthotics and prosthetic practice and provides the analytical
basis for the written simulation and clinical patient management
examinations. The Practice Analysis is available at no cost from ABC and is
provided to all examination candidates.

Continuing education requirements are listed below:

ABC has long recognized the need for effective professional continuing
education. Continuing education, which is the norm in the health care
profession, is meant to maintain and improve the healthcare system and
delivery of services. ABC credentialed individuals must seek education to
meet two continual demands: 1) to maintain performance at the basic level of
professional competence; and, 2) to advance training and specialized skills
beyond the basic level.

The content of continuing education program is within the body of knowledge
and skills generally recognized and accepted by the profession as
encompassing the basic sciences, the discipline of clinical orthotics,
prosthetics and Pedorthics, and the provision of healthcare to the public.
Included are programs that provide leading edge scientific information that
is at the forefront of research in the O&P profession. This definition and
the rules applied to the continuing education programs are sufficiently
broad to permit O&P professionals to undertake continuing education
activities relevant to their professional responsibilities. All continuing
education opportunities submitted for recognition should comply with this
definition. Single Discipline (CP or CO) Practitioners: 1. Seventy-five (75)
credits must be earned during the five year cycle. At least two-thirds (50)
of the required credits must be Category I scientific credits. 2. One-third
(25) may be Category II credits. Although an unlimited number of credits may
be earned during each five year period, no more than 25* Category II credits
will be counted toward satisfying the continuing education requirement. 3. A
maximum of 25* credits may be Business credits. These may be either Category
I or Category II, however they may not be counted toward satisfying the
required 50 Category I scientific credits. Dual Discipline (CPO)
Practitioners: 1. One hundred (100) credits are required within the five
year cycle. A minimum of seventy-five (75) credits must be Category I
scientific credits. Although an unlimited number of credits may be earned
during each five year period, no more than 25* Category II credits will be
counted toward satisfying the continuing education requirement. 2. Of the
total number of credits required for MCE, a maximum of 25* credits may be
Business credits. These may be either Category I or Category II, however
they may not be counted toward satisfying the required 75 scientific
credits.

It is the belief of myself and our clinic that in order to provide services
to patients of CMS that the above educational, residency, board exams, and
continuing educational requirements should be met. This ensures that a base
knowledge and skill set has been obtained by the Orthotic and Prosthetic
practitioners. Without these standards CMS will not have a good method of
ensuring proper care.

Thank you for your time and consideration I hope this will make it into your
standards.

Sincerely Eric Hammerschmidt CPO

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Whether you agree with these comments or not please respond to CMS so we
can help to set Quality Standards. Thanks

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