AOPA Submits Comments on CMS’ Qualified Provider Proposal


CMS LogoOn March 13, AOPA submitted comments on the CMS proposal “Proposed Rule on Medicare Requirements for Qualified Practitioners and Qualified Suppliers of Prosthetics and Custom-Fabricated Orthotics”. This is the proposal that would enact the long awaited provisions of Section 1834(h) of the Social Security Act, which establishes requirements for qualified suppliers and qualified practitioners, and restricts payments to providers who don’t meet those criteria.

AOPA gathered member input on the rule and prepared pre-written comments for members to submit through the AOPAvotes.org platform- 181 members submitted comments to CMS through AOPAvotes.org.

AOPA submitted its own comments that reflect our support of the rule, which is the first step toward ensuring that only qualified providers and suppliers provide prostheses and custom fabricated orthoses to Medicare beneficiaries. AOPA’s comments include our opinion that the rule as written is overly broad and should include exceptions, and includes AOPA’s concerns with enforcement mechanisms, the “equivalency to ABC or BOC standards”, and the regulation of fabrication of O&P devices. Read AOPA’s Comments.