Wednesday, May 25, 2022


Morris Gallo

To all list members.
Last year there was a furor in the O&P press and this list over the passage of language in the Medicare bill that would define what are “Qualified” prosthetists and orthotists, and what items should be limited to these “Qualified” individuals. The statutory language identified physicians, PT’s, OT’s, ABC and BOC certified prosthetists/orthotists, licensed prosthetists/orthotists, and others identified by the Secretary of Health as qualified to provide these yet to be determined items. All prosthetics are included, only certain “custom made” orthotics are yet to be named. There was no mention of what constituted appropriate education or training, this may be determined by the Negotiated Rulemaking Committee.

The following have been named by the convener as organizations forming the rulemaking committee:

* ABC Certification body that grants the CP/CO/CPO designations and
has established an examination process based on specified education
and training requirements.
* BOC Certification body that has an examination process based on
the individual’s experience.
* National Community Pharmacy (NCP) Association of independent
retail pharmacists/pharmacies, used to be called NARD, has
historically been involved in O&P only from the point they retail
premade non-custom orthoses.
* National Commission of Orthotic and Prosthetic Education (NCOPE)
The commission that establishes the education requirements for O&P
education programs to insure patient safety.
* American Academy of Orthotists and Prosthetists (AAOP) The
organization that advocates for the CP/CO/CPO, for the consumer,
and on behalf of the educational process to insure the practitioner
has the minimal education and training to insure patient safety.
* National Association for the Advancement of Orthotists and
Prosthetists (NAAOP) An organization of O&P practitioners whose
goal is to advocate for the consumer and the practitioner.
* American Physical Therapy Association (APTA) The official
national organization lobbying for the member physical therapist.
* American Orthotic and Prosthetic Association (AOPA) A trade
organization representing practitioners (ABC, BOC, and also
non-certified practitioners), member businesses, and
manufacturers. They deal mainly with business related issues.
* National Orthotic Manufacturers Association (NOMA) A small trade
association that lobbies for the five or six unnamed manufacturers
of primarily premade orthoses.
* International Association of Orthotics and Prosthetics (IAOP) A
trade association closely aligned with BOC that conducts annual
* Hanger Prosthetics Public corporation, the largest chain of O&P
patient care facilities in the US.
* Point Health Centers A member coop organized to advocate for its
member facilities, primarily in healthcare contracts.
* Coalition of Illinois and Florida certification boards An
artificial coalition named to represent those states having O&P
licensure and their licensed practitioners.
* Coalition of State associations representing orthotists and
prosthetists A coalition of unnamed O&P State Associations.
* Paralyzed Veterans of America (PVA) National organization
representing the paralyzed veterans and their families.
* National Association for Long Term Care (NALTC) A trade
association that lobbyies for the nursing home industry.

For your information I added (in italics) a short description of the groups .

Under Federal law everyone is entitled to send comments to the committee and supposedly these comments may influence the committee and the eventual outcome. Below are links to the actual language and addresses of where to send comments. I urge all interested parties, both practitioner and patient, to send comments.

You should consider the following:

* The only “consumer” representative is the PVA. Why are amputees
and other consumers not represented?
* There are several organizations (NCP, NOMA, and NALTC) that do not
represent practitioners or consumers. They also do not represent
any business interest that has to do with the provision of CUSTOM
orthotics or prosthetics, so why are they included in the policy
making process?
* The process will establish what is defined as a “qualified” O&P
provider, yet the two certification bodies (ABC and BOC) have
diametrically opposite ideas as to what constitutes appropriate
education and training. ABC requires a college degree and formal
O&P training, while BOC requires only short-term undefined
experience with no formal education or training. Should the
resulting rules require a specified level of education and
training, or is the attainment of the ABC or BOC certification all
that is needed to be termed “qualified”? Should there be a
distinction between the new practitioner and the old-timer?
* PT’s do not receive any O&P education or training outside of a few
hours and whatever second-hand info they pickup in clinics.
Individual PT’s may seek additional training, usually provided by
manufacturers in brief seminars, but remember they will all be
treated equally without regard to post-graduate training. Should
PT/OT be required to demonstrate a defined level of education,
formal training, and having passed an examination in O&P before
they can be termed “qualified”?
* OT’s receive training in “splinting” but how does that qualify them
to provide prosthetic or comprehensive custom orthotic care?

The above are some of the things that need to be discussed and your input into the process is of the most importance. Read the actual language and make sure you note the nuances of the verbiage.

Below you will find the URL for the March 22, 2002, Federal Register Announcements – Negotiate Rulemaking Process for the “Establishment of Special Payment Provisions and Standards for Suppliers of Prosthetics and Certain Custom-Fabricated Orthotics.”


As you will read in the document the comment period will end @ 5:00 PM, April 22, 2002. Your comments must be sent and received according to the instructions below.

DATES: Comments will be considered if we receive them at the appropriate address, as provided below, no later than 5 p.m. on April 22, 2002.

ADDRESSES: Mail written comments (1 original and 3 copies) to the following address: Centers for Medicare & Medicaid Services, Department of Health and Human Services,
Attention: CMS-6012-NOI,
P.O. Box 8013,
Baltimore, MD 21244-8013.

Mail a separate copy of written comments to the following address: Kathryn Cox, Office of Financial Management, Mail Stop C3-02-16, Centers for Medicare & Medicaid Services, 7500 Security Boulevard, Baltimore, MD 21244.

Please allow sufficient time for mailed comments to be timely received in the event of delivery delays. If you prefer, you may deliver your written comments (1 original and 3 copies) by courier to one of the following addresses: Hubert H. Humphrey Building, Room 443-G, 200 Independence Avenue, SW., Washington, DC,

Room C5-14-03,
7500 Security Boulevard,
Baltimore, MD 21244-1850.

(Because access to the interior building is not readily available to persons without Federal Government identification, commenters are encouraged to leave their comments in the CMS drop slots located in the main lobby of the building. A stamp-in clock is available for commenters wishing to retain proof of filing by stamping in and retaining an extra copy of the comments being filed.) Comments mailed to the addresses indicated as appropriate for hand or courier delivery may be delayed and could be considered late. Because of staffing and resource limitations, we cannot accept comments by facsimile (FAX) transmission. In commenting, please refer to file code CMS-6012-NOI.

When you send your comments be certain to identify yourself, where you live, and your association with O&P. This is very important as it will establish a precedent that will be felt throughout the country, even though it is only directed at Medicare. This is similar to the way the Medicare fee schedule is used as the standard throughout the industry.

If you are a member of other related lists feel free to forward this message


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