Re: Comments to the Proposed DPW-Pennsylvania Durable Medical Equipment Request for Proposal

To: Estelle B. Richman, Secretary
Department of Public Welfare
c/o Suzanne Love, Project Manager
Harrisburg State Hospital

CherryWood Building
Harrisburg, PA 17105

Dear Ms. Richman:

On behalf of the National Association for the Advancement of Orthotics and Prosthetics (NAAOP), I am writing to urge you to consider exemption of orthotic and prosthetic (O&P) items and services under the proposed request for proposal (RFP). NAAOP is a national non-profit association representing the collective interests of certain specialized clinicians who are engaged in the provision of quality O&P healthcare. Specifically, NAAOP represents highly trained and educated clinicians who carefully evaluate both limb loss and limb or trunk dysfunction for the purpose of providing appropriate, custom-designed orthoses (orthopedic braces) and prostheses (artificial limbs). These clinical services often mean the difference between functional independence and long-term disability for people with amputations, musculoskeletal conditions, neurological disorders, stroke, and large numbers of congenital and acquired physically disabling conditions.

NAAOP is concerned that the selective contracting of O&P services would greatly limit patient access to highly trained orthotists and prosthetists who currently provide quality, customized O&P care. Since most orthotics and virtually all prosthetic services are customized to individual patients and require highly specialized knowledge to assure patient rehabilitation and health, competitive bidding of such services will be virtually impossible. On a national level, the Medicare program has implemented a durable medical equipment (DME) competitive bidding program that specifically exempts most orthotics and all prosthetic services. We would like to focus our comments on several specific issues relating to competitive bidding and its impact on patients and providers of O&P services.

Simply put, price cannot be the sole determining factor in awarding a competitive bidding contract. O&P is ultimately a service-based industry that relies upon highly specialized and trained providers who undergo years of rigorous training. Competitive bidding will force some providers to drop many of their patients, sacrificing the quality and range of choices for beneficiaries all in the name of a low bid. Inevitably, low-ball bidders will provide substandard care. Furthermore, competitive bidding may actually cost Pennsylvania more than the current system due to increased patient visits, replacements necessitated by substandard products/poor patient training, or ill-fitting orthoses. Competitive bidding that involves professional services will foster a “race to the bottom,” not a race for the best outcome.

Competitive bidding, as defined in the state’s proposal, is ultimately about choice. NAAOP believes that choice incorporates multiple factors: choice of provider, choice of product, and choice based on price. The Pennsylvania proposal determines that price should be the sole factor for choosing appropriate O&P providers for patients. With this determination, long-standing relationships between beneficiaries and familiar providers who know patients’ special needs and which product serves patients best are lost. There will be interruptions in service and access to a wide range of O&P products will be limited. Providers who submit the lowest bids will inevitably chose the cheapest materials and quickest methods to fit their patients. Patient choice is the ultimate arbiter of quality O&P care since beneficiaries will ultimately chose the providers who provide the most cost-effective and quality care.

Thank you for considering our comments as Pennsylvania moves forward with its competitive bidding efforts. If we can provide further assistance or technical advice concerning this or other proposals, please do not hesitate to contact our General Counsel, Peter W. Thomas, at 202-466-6550 or peter.thomas@ppsv.com

Sincerely,
Peter W. Thomas

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