AOPA submitted comments on October 17, 2025, to the U.S. Department of Commerce regarding the Section 232 National Security Investigation on Imports of Personal Protective Equipment (PPE), Medical Consumables, and Medical Equipment (BIS-2025-0248) urging them to exclude custom O&P in their national security probe.
AOPA urged the Bureau of Industry and Security (BIS) to exclude orthoses and prostheses from this investigation, emphasizing that they are custom-fabricated, patient-specific medical devices rather than mass-produced equipment like PPE or consumables. We explained that O&P care is a highly specialized, clinical process involving a multidisciplinary team of rehabilitation professionals. Unlike other medical devices, every prosthesis and orthosis are custom fit, assembled, and delivered in the U.S., meaning they pose no realistic national security risk.
We argued that concerns over foreign supply chains, subsidies, or export restrictions are largely irrelevant to O&P, since imports of O&P components represent a negligible volume and are not subject to predatory trade practices. We also warned that imposing tariffs, quotas, or trade restrictions could increase provider costs within a fixed Medicare reimbursement system, ultimately harming patient access to essential care.
In closing, we reaffirmed O&P’s commitment to patient-centered, evidence-based care and cautioned that including O&P devices in the Section 232 investigation could have unintended consequences for veterans, service members, and millions of Americans living with limb loss or difference. We concluded by stating that these were the reasons we strongly recommend O&P devices be excluded from the investigation to avoid disrupting clinical care and patient outcomes.