Submit comments on the CMS proposed changes to the DMEPOS quality standards that would include a 14% reduction in reimbursement for custom fabricated, direct milled diabetic inserts. In July, the DME MACs released a clarification stating that diabetic inserts billed using A5513 must be molded over an actual model of the patient’s foot. At that time, the DME MACs stated that the use of generic, electronic or “virtual” models where custom fabrication occurs without creation of a physical model of the patient’s foot did not meet the code descriptor for A5513.
AOPA has been in touch with CMS to voice our concern over this issue, and in September CMS proposed a change to the quality standards to allow for the use of digital or virtual models in combination with a direct milling process to meet the definition of “molded to patient model.” However, in a FAQ document, CMS indicated that inserts that were fabricated using a direct milling process would be reimbursed approximately 14% lower than those that were molded over a physical model of the patient’s foot which takes a “toll” on providers who chose to provide direct milled inserts that are identical to inserts fabricated using the older technology of molding the insert over a model of the patient’s foot.
CMS has indicated that it intends to finalize the proposed changes by January 1, 2018, and is taking comments under December 11. AOPA has prepared comments that can be submitted on AOPAvotes.org.