Recently, the United States Department of Veterans Affairs (VA) published a document that creates new payment policies for O&P services, including those described by Not Otherwise Classified (NOC) codes, pedorthic services, and certain products described by HCPCS codes that the VA acknowledges are not adequately reimbursed under the current Medicare fee schedule. The updated payment policies for NOC codes and outlier products are based on a sliding scale that includes the manufacturer’s invoice and a designated mark-up fee. The communication also indicates that the VA will reimburse community providers at 100% of the Medicare fee schedule, eliminating the need for negotiated discounts. AOPA staff has maintained an open dialogue with VA officials regarding the new VA community provider standard and received a response to AOPA’s and other organizations questions on September 11, 2026, with the release of a frequently asked questions document.

Several items worth noting from the FAQ include the following:

  • Vendors will have the option to terminate any existing VA contracts early to participate in the new community-based provider program, including the revised non-discounted reimbursement rates and NOC code reimbursement policy.
  • Contracted Vendors can elect to continue to operate under the terms of their existing contracts for the remainder of the contract term.
  • Community-Based providers must meet the revised standards to continue to serve veterans.
  • The community-based care model will replace all contracts and blanket purchase agreements (BPA) moving forward.

The VA community-based provider standard represents a strong effort by VA leadership to continue to build collaborative relationships with O&P providers based in the community and creates consistent policy across the entirety of the Veterans Integrated Services Networks (VISNs). AOPA remains hopeful that this new standard will contribute to the provision of the best clinical care available to veterans and significantly less administrative burden for O&P providers and VA officials. Additionally, AOPA staff will continue to work with our VISN Liaisons to monitor the impacts of these changes as well as others and welcomes feedback from members at any time.

Questions regarding the new community-based provider standard may be sent to Joe McTernan at jmcternan@aopanet.org or Devon Bernard at dbernard@aopanet.org.