Month: October 2018

The Centers for Medicare and Medicaid Services has announced that it will hold a special Open-Door Forum conference call to educate the public about a new initiative tasked with developing an online resource where providers and suppliers can look up the documentation requirements necessary for Medicare to cover a service or item.  While the initiative is still in the early stages of development, CMS has indicated that it is interested in receiving feedback from the public as it develops this initiative.

AOPA will be represented on the conference call and will provide a report to AOPA members upon its conclusion.  The call is scheduled for 2pm until 3pm EDT on Tuesday, October 23, 2018.  The conference call dial in number for anyone who wishes to participate is 1-800-837-1935 and the participant ID is 7277693.  The call is open to the public and no pre-registration is required.

As stated earlier, AOPA will be represented on the call and will provide a report to its members on the content of the call.

The CMS announcement regarding the Special Open-Door Forum call may be viewed HERE

Questions regarding this issue may be directed to Joe McTernan at jmcternan@aopanet.org or Devon Bernard at dbernard@aopanet.org.\

The four Durable Medical Equipment Medicare Administrative Contractors (DME MACs) have recently released a revised version of the “Dear Physician” letter that addresses the need for prescribing physicians to support the medical necessity of the DMEPOS services they prescribe through proper clinical documentation in the patient’s medical record.  While the revisions to the Dear Physician letter were not significant from previous versions of the long-standing letter, the revision provides a reminder that for DMEPOS items or services to be covered, they must always be supported by physician documentation.

O&P won a battle in February 2018, with the enactment of Section 50402, which recognized the clinical notes of orthotists and prosthetists as part of the medical record for purposes of medical necessity determinations.  While the legislative change essentially reset the clock back to 2011 and reversed the now retired Dear Physician letter for lower limb prostheses that said that O&P notes were not considered part of the medical record, Section 50402 DID NOT convey to O&P prescribing rights and DID NOT eliminate the need for physician notes supporting the medical need for O&P services they prescribe.  Section 50402 specifically indicates that while orthotist and prosthetist notes are now part of the medical record, they are corroborative, and cannot, standing alone, trigger a finding of medical necessity.

The recognition of orthotist and prosthetist notes as part of the medical record is a long sought-after result, and one of great pride for AOPA but it is important to remember the crucial role of physician partners in documenting the medical need for O&P services they prescribe.

The revised Dear Physician letter regarding general documentation was just one of many minor revisions made to the Dear Physician letters.  Most of the revised Dear Physician letters do not apply to O&P services.  This includes the recently revised Dear Physician letter regarding face-to-face visit and written orders prior to delivery for certain DMEPOS items.  It is important to remember that these specific requirements do not apply to O&P services as O&P services are specifically exempt from these requirements.

AOPA continually monitors the DME MAC websites for substantive changes to the Dear Physician letters that affect O&P providers and will communicate them to AOPA members immediately.

The revised Dear Physician letter on general documentation requirements may be viewed by clicking HERE.

Questions regarding this issue may be directed to Joe McTernan at jmcternan@aopanet.org or Devon Bernard at dbernard@aopanet.org

The American Orthotic & Prosthetic Association (AOPA) in partnership with The Journal of Neuroengineering and Rehabilitation, JNER, a BioMed Central journal partner, is pleased to announce that the supplement, “Advancements in Prosthetics and Orthotics: Selected articles from the Second World Congress hosted by the American Orthotic & Prosthetic Association (AOPA)” has been published today. The full content of the supplement can be found at http://bit.ly/AdvancementsinOP.

Presenters of the identified papers were invited to submit their full manuscript to the JNER for rigorous peer-review and consideration for publication in a special topic edition on prosthetics and orthotics that would capture the essence of the 2017 World Congress. The goal of this special topics edition was to afford the scientific and clinical communities the opportunity to take a “deeper dive” into the detail of the top presentations of the 2017 AOPA World Congress. These topics were regarded as cutting-edge topics ranging from exercise testing and cardiovascular events in patients with limb loss to gait assessment and novel therapies such as use of a virtual environment during rehabilitation. Additionally and importantly, economic evaluations for orthotic and prosthetic devices are also included.

Numerous stakeholders are responsible for facilitating development of this special issue of JNER. The guest editorial board wishes to thank AOPA and its volunteer content committee for vetting and identifying its top papers and presenters, the American Board for Certification in Orthotics, Prosthetics and Pedorthics, Inc. for its generous sponsorship, to the authors for submitting their work and of course to the JNER team for their partnership. It is our hope that the entire community of stakeholders in prosthetics and orthotics benefit from the findings contained in this edition of the JNER.

Questions? Please contact Yelena Mazur, AOPA’s Communications Specialist at 571/431-0835 or ymazur@AOPAnet.org.

On October 1, 2018, AOPA submitted comments on a draft policy governing coverage of lower limb prostheses, including microprocessor-controlled prostheses issued by Health Care Services Corporation (HCSC), which operates Blue Cross Blue Shield of Illinois, Texas, Montana, New Mexico, and Oklahoma. The draft policy, as written will significantly reduce access to advanced prosthetic technology for BCBS subscribers in these five states. AOPA expressed its concern regarding the draft policy in its comments which are summarized below and linked at the end of this article.

AOPA’s first concern is that HCSC published the draft policy on September 15, 2018 with comments due no later than October 1, 2018. AOPA commented that 15 days was not sufficient time to perform a complete review of the draft policy and provide informed comments. AOPA suggested a minimum 60-day comment period to allow stakeholders adequate time to comment on the draft policy. Despite the unrealistic deadline, AOPA submitted comprehensive comments regarding the draft policy and negative impact it will have on BCBS subscribers.

AOPA commented that the draft policy is unnecessarily restrictive and will limit access to advanced technology, especially to BCBS subscribers who may be classified as limited community ambulators (K2) but may benefit more from receiving microprocessor-controlled prosthetic knees. AOPA refenced studies published by the RAND Corporation, the health economics firm Dobson-DaVanzo, and the Mayo Clinic that showed that the use of microprocessor-controlled knees by limited community ambulators reduced the rate of falls and fall related injuries. The draft policy would effectively eliminate BCBS coverage except for patients who were assessed as high functioning community ambulators (top percentage of K3 patients).

AOPA’s comments also referenced the recent report of the inter-agency workgroup that was convened to provide a consensus statement on Medicare coverage of lower limb prostheses after the Medicare draft LCD was released several years ago. The inter-agency workgroup recommended the potential creation of a National Coverage Determination that would address Medicare coverage of microprocessor knee in K2 patients. AOPA’s comments expressed concern that restricting access to advanced prosthetic technology was not in BCBS’ best interest nor the best interest of their subscribers as it was contradictory to the consensus statement of the inter-agency workgroup and the overall health of their subscribers.

AOPA is hopeful that HCSC will seriously consider AOPA’s comments before publishing the final version of the policy revision.

AOPA’s complete comments may be viewed here.