The Pedorthic Footwear Association (PFA) has recently issued a call to action suggesting that their members contact ABC to ask us to get in touch with CMS in support the PFA’s proposal regarding the mandatory accreditation requirement for pedorthists. ABC agrees that the short deadline imposed on pedorthists by CMS was burdensome. We have contacted CMS about this deadline on several occasions, but they remain steadfast in their adherence to the set deadline. ABC has worked very hard to educate pedorthists about the mandatory accreditation deadlines, the standards for accreditation, and the steps necessary for accreditation compliance.
ABC has also worked closely with CMS on the proposed quality standards and revisions of the 855S form. We have spent numerous hours communicating to CMS the different types of orthotic, prosthetic and pedorthic credentials and the education, training and competency assessments required for each professional.
ABC disagrees with PFA’s erroneous assertion that CMS rescinded the exemption because facilities staffed by Certified Fitters of Therapeutic Shoes (CFts) are being accredited as pedorthic facilities. ABC does not accredit facilities as pedorthic facilities unless a pedorthic professional is responsible for patient care. Those facilities where a CFts is responsible for care are accredited in the Non Custom Therapeutic Shoe accreditation program and the CFts must be working within their defined Scope of Practice. CMS relies on Deemed Authorities such as ABC to appropriately accredit facilities and relay that information back to CMS. If the 855S form indicates “pedorthist” but there is no one appropriately credentialed or licensed on staff, ABC will not accredit that facility as a pedorthic facility. As mentioned above, ABC contacted CMS several times to ask that all orthotic, prosthetic and pedorthic provider types be listed on the revised 855S form, however these measures were not adopted by CMS.
We believe it is important to clarify another incorrect statement made by the PFA. The assertion that certified fitters are somehow exempt from both mandatory accreditation and the surety bond issue is incorrect. Further, the PFA stated that orthotic fitters can bill pedorthic codes. ABC’s accreditation and certification programs do not allow orthotic fitters to provide diabetic shoes or comprehensive pedorthic services. We pay strict attention to the qualifications of the facility’s care providers and if it is discovered that an organization is providing services that exceed those qualifications we will revoke their ABC accreditation.
ABC continues to work closely with CMS on the issues surrounding facility accreditation, qualified provider regulation, appropriate reimbursement criteria and other issues related to orthotics, prosthetics and pedorthics. While we appreciate the opportunity to hear from the pedorthic community, we suggest that the PFA’s call to action would have been more effective if generated before the 1/31/09 deadline and if PFA members had been directed to contact CMS, and not ABC—an organization dedicated since 1948 to establishing and promoting the highest standards of organizational and clinical performance in the delivery of orthotic, prosthetic and pedorthic services.