Update: Orthotist/prosthetist notes will be considered part of the patient’s medical record by CMS!


It’s official! As a follow-up to yesterday’s announcement, with the overnight action of both Senate and House in enacting the Continuing Resolution and the spending bill, and with President Trump having signed that legislation, not only is the federal government open, but the following O&P provision is now officially signed into law:

SEC. 50402. ORTHOTIST’S AND PROSTHETIST’S CLINICAL NOTES AS PART OF THE PATIENT’S MEDICAL RECORD.
13 Section 1834(h) of the Social Security Act (42 U.S.C. 1395m(h)) is amended by adding at the end the following new paragraph:”
(5) DOCUMENTATION CREATED BY ORTHOTISTS AND PROSTHETISTS. – For purposes of determining the reasonableness and medical necessity of orthotics and prosthetics, documentation created by an orthotist or prosthetist shall be considered part of the individual’s medical record to support documentation created by eligible professionals described in section 1848(k)(3)(B).”.

Even with this one sentence, straightforward provision, there may be questions of timing applicability and such to be resolved – but the win is complete. The Orthotist and Prosthetist Notes are now officially part of the medical record for purposes of Medicare medical necessity and claims audits!

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