Proposed Payment Changes for Orthotics and Prosthetics

Posted by ASHT Practice Division on 01/23/2017

CMS published a new proposed rule that could severely limit the ability of hand therapists to be paid for custom-fabricated orthoses. Rule CMS-6012-P “Establishment of Special Payment Provisions and Requirements for Qualified Practitioners and Qualified Suppliers of Prosthetics and Custom Fabricated Orthotics,” published in the Federal Register January 12, 2017, removes exemptions to quality standards and orthotic certification for OTs and PTs, and would require licensure in orthosis fabrication by the state or the American Board for Certification in Orthotics and Prosthetics or the Board for Orthotist/Prosthetist Certification or a program “approved by the HHS Secretary.” Suppliers who do not meet the standard will not receive payment for custom-fabricated orthoses, and may face revocation of both their Medicare and DMEPOS eligibility. ASHT, in conjunction with HTCC, APTA’s Hand Academy and AOTA, are drafting comments on the proposed rule and will update members as more information is revealed.

Learn more from CMS

How you can help: Review your state practice acts to determine if orthosis fabrication is included in your scope of practice. Please contact ASHT if your practice act does not specify orthosis fabrication.

ASHT President Gary Solomon discusses Rule CMS-6012-P in a new video on the ASHT Facebook page

Comments

Comment: 
"Occupational therapy", the use of purposeful activity or interventions designed to achieve functional outcomes which promote health, prevent injury or disability and which develop, improve, sustain or restore the highest possible level of independence of any individual who has an injury, illness, cognitive impairment, psychosocial dysfunction, mental illness, developmental or learning disability, physical disability or other disorder or condition. It shall include assessment by means of skill observation or evaluation through the administration and interpretation of standardized or nonstandardized tests and measurements. Occupational therapy services include, but are not limited to: (a) The assessment and provision of treatment in consultation with the individual, family or other appropriate persons; (b) Interventions directed toward developing, improving, sustaining or restoring daily living skills, including self-care skills and activities that involve interactions with others and the environment, work readiness or work performance, play skills or leisure capacities or enhancing educational performances skills; (c) Developing, improving, sustaining or restoring sensorimotor, oral-motor, perceptual or neuromuscular functioning; or emotional, motivational, cognitive or psychosocial components of performance; and (d) Education of the individual, family or other appropriate persons in carrying out appropriate interventions. Such services may encompass assessment of need and the design, development, adaptation, application or training in the use of assistive technology devices; the design, fabrication or application of rehabilitative technology such as selected orthotic devices, training in the use of orthotic or prosthetic devices; the application of ergonomic principles; the adaptation of environments and processes to enhance functional performance; or the promotion of health and wellness;

Comment: 
(9) designing, fabricating, or applying rehabilitative technology, such as selected orthotic and prosthetic devices, and providing training in the functional use of these devices;

Comment: 
(5) Designing, fabricating, applying, recommending, and instructing in the use of selected orthotic or prosthetic devices and other equipment which assists the individual to adapt to the individual’s potential or actual impairment;