ABC recently submitted comments to the Centers for Medicare & Medicare Services Department of Health and Human Services (CMS) regarding accreditation requirements proposed in CMS-1270-P. We emphasized that O&P accreditation should recognize the independent practice of certified orthotic and mastectomy fitters. We stressed the need for recognition of different levels of patient care; from comprehensive to off-the-shelf orthoses. Those levels would improve accessibility to certain orthoses and therapeutic shoes which require lesser skills and involve lower patient risk while assuring the beneficiary that suppliers have personnel who are qualified to provide services at the appropriate level of competency. It would further require an accrediting organization to ensure that the site of care has the appropriate specialized equipment and facilities to provide patient care at the level required for the various categories.
Further, our comments requested that CMS create a stronger tool than a mere checklist of compliance with quality standards. We believe that the accreditation process should include reasonable mechanisms to identify those suppliers which possess the competency to provide orthoses at various levels of complexity whereas the checklist would be applied to all O&P suppliers regardless of the complexity.
We offered the Orthotic and Prosthetic Scope of Practice and asked CMS to consider the classification of O&P billing codes as endorsed by ABC, AOPA, the Academy and NAAOP.
In addition, ABC is proud to have participated with the O&P Alliance in commenting on the CMS proposed rule regarding the implementation of competitive bidding and the imposition of quality standards on all DMEPOS suppliers. ABC remains opposed to the inclusion of any form of O&P care in the competitive bidding program and supports the requirement for uniform application of the quality standards to all O&P suppliers.