Fellows Report Progress and Say Farewell While CMS Drops Alarming DMEPOS Proposed Regulation

The 2019 NAAOP Fellows, Alicia Carver and Susannah Engdahl, finished their fellowship last week and report learning a great deal about O&P policy and advocacy throughout the course of the summer.  NAAOP extends sincere thanks to the Alliance organizations for hosting the fellows, as well as numerous contributors and hosts across the country who exposed them to all aspects of orthotics and prosthetics.

Alicia Carver:  Alicia’s principal project this summer involved direct federal advocacy on the soon-to-be-introduced Medicare O&P Patient-Centered Care Act.  Alicia and Susannah joined forces to visit over 35 House and Senate offices to promote the policies in the bill and to seek cosponsors of the legislation.  The meetings focused on the three major committees of jurisdiction over the bill, the House Ways & Means Committee, the House Energy & Commerce Committee, and the Senate Finance Committee.  In fact, the fellows’ last meeting was conducted alongside OPGA’s lobbying team with the chief health staffer of Senate Finance Committee Chairman Charles Grassley (R-IA).  All of the hill meetings were coordinated with the O&P Alliance and with AOPA’s efforts in spearheading the bill.

Susannah Engdahl:  Susannah’s principal project this summer involved the development of a compilation of clinical and economic evidence from academic literature to demonstrate the value of O&P care for use in advocacy materials.  Citations to the evidence base are critical in making compelling policy arguments and Susannah’s work product this summer will inform NAAOP’s policy and advocacy efforts well into the future.

CMS Issues DMEPOS Proposed Rule

On July 29, 2019, the Centers for Medicare and Medicaid Services (CMS) released the proposed rule containing updates to the Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) regulations. The full text of the rule can be found here, and a CMS fact sheet summarizing the major provisions in the rule can be found here. Comments on the proposed rule are due September 27, 2019 and can be submitted electronically by following this link or visiting www.regulations.gov and searching “CMS-1713-P.”

The rule includes a number of provisions that impact orthotics and prosthetics (O&P).  Unfortunately, the rule again applies DME-centric policies to O&P care, thereby increasing the importance of our legislative push to further separate DME from O&P.  The most significant proposals involve a new process for calculating payment amounts for new technologies receiving HCPCS codes (“gap-filling”) which may create a major disincentive for innovators to invest in bringing new O&P technologies to market.  The proposed rule also includes a new consolidated list of DMEPOS eligible for prior authorization.  In addition to the 82 L-codes already eligible for prior authorization, CMS adds 144 new L-codes to the Master List, with little justification.  NAAOP will be working with its Alliance partners to respond forcefully to this proposed rule.

Thank you again for your support of NAAOP and our Fellowship Program.  And thank you to Alicia and Susannah for bringing their skills, enthusiasm, dedication, and personal knowledge of O&P care to Washington, DC.

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