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.