AOPA in AdvanceBreaking News for O&P Professionals
January 26, 2007 ♦ SPECIAL EDITION
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A Joint Letter from the O&P Alliance to the
Orthotic and Prosthetic Profession
The
four member organizations of the O&P Alliance (AAOP, ABC, NAAOP and
AOPA) write this joint letter to inform our respective members about
the status of Medicare DMEPOS supplier accreditation, quality
standards, and competitive bidding. There has been considerable confusion and misinformation in the field on these important issues and this letter is intended to clarify the situation as of this date. It is important to note two things: 1) that this situation is changing rapidly from day to day as CMS implements these new policies, and 2) that your national associations are actively working, in alliance, to advance your interests.
Competitive bidding for DME, supplies and some orthotics was enacted by Congress in the Medicare Modernization Act of 2003 (“MMA”) and is scheduled to be phased-in beginning in October 2007 in ten cities (i.e., Metropolitan Statistical Areas or “MSAs”) throughout the country. These ten cities have not yet been announced although CMS has informally suggested that they will be chosen from a broader list of 28 MSAs under consideration. Rumors in the field that CMS has already selected these ten cities are false.
Prosthetics are completely exempted from competitive bidding by law and many orthotics are as well. CMS has not yet announced which orthotics will be included in competitive bidding but the MMA law states that only “off-the-shelf orthotics” may be included. The term “off-the-shelf orthotics” is defined in the law so CMS must adhere to this definition when it interprets which orthotics are considered “off-the-shelf.” The O&P Alliance is actively working to ensure that the list of orthotic codes that are included in competitive bidding is as short as possible.
Under competitive bidding, suppliers will submit bids to the government to provide items and services to Medicare beneficiaries for reduced fee schedule rates. In exchange, CMS will select a limited number of suppliers for a given MSA. To help ensure that suppliers do not skimp on the care they provide beneficiaries, Congress mandated that CMS create quality standards. CMS will ensure that suppliers in the competitive bidding program are meeting the quality standards through an accreditation model. In fact, this past November, CMS selected 11 private organizations, including ABC, to accredit certain DMEPOS suppliers. A list of the 11 organizations is attached.
All suppliers wishing to participate in the competitive bidding program must be accredited and meet the quality standards and, so, CMS will require accreditation first in those MSAs that are selected for competitive bidding. O&P suppliers in the 10 selected MSAs who do not participate in supplying off-the-shelf orthotics through competitive bidding are not immediately required to become accredited.
However, ALL DMEPOS SUPPLIERS, including all O&P suppliers, must become accredited eventually if they intend to continue participating in the Medicare program, whether or not they participate in competitive bidding. It is not known when CMS will enforce this accreditation requirement by discontinuing Medicare payment to suppliers who are not accredited, but this is likely to be years away. At present, only a small percentage of Medicare’s DMEPOS suppliers are accredited.
There are numerous, complex issues still unresolved and numerous decisions to be made as CMS implements this set of policies. There are also many unknowns at this time. For instance, several organizations selected to accredit DMEPOS suppliers have little or no experience with accreditation, let alone accreditation of O&P facilities. The learning curve for these organizations will be steep and some are likely to discontinue their interest in O&P as the complexities become clear.
ABC and the other ten selected accrediting organizations are in a difficult position at this point. CMS has stated that it expects all suppliers who will be participating in competitive bidding to be accredited by April 2007. But the ten MSAs for competitive bidding have not yet been announced, the list of orthotic codes defined as “off-the-shelf” has not been determined, and CMS has recently suggested its interest in revising the quality standards that apply to orthotics and prosthetics. In addition, it is not clear at this time whether every MSA will include competitive bidding of off-the-shelf orthotics.
You may be contacted by one or more of the 11 accrediting organizations selected by CMS urging you to avoid delay in becoming accredited. We would like to collectively stress that at this point in time, it is important to proceed in a deliberate manner, to keep informed of new developments through your national associations, and to keep the implementation of these new policies in perspective.
We hope this letter lessens the confusion surrounding these issues in the O&P profession. Suffice it to say, we share your frustration with the uncertainties and misinformation and will continue to inform you of developments as they occur. Please contact any of the four groups that comprise the O&P Alliance for further assistance.
Sincerely,
Ronald Ted Snell, CP, President, AOPA
Mark D. DeHarde, President, NAAOP
Stephen B. Fletcher, CPO, President, ABC
Gary M. Berke, MS, CP, FAAOP, AAOP
DMEPOS Accreditation Organizations
Selected By CMS
Selected By CMS
The following organizations will accredit suppliers of durable medical equipment, prosthetics, orthotics and supplies (DMEPOS). Not all of these agencies are approved for ALL aspects of O&P care.
1. American Board for Certification in Orthotics & Prosthetics, Inc. (All O&P)
Contact Person: D. Scott Willamson, Jr., CAE
Director, Facility Accreditation, IS & Discipline
330 John Carlyle Street, Suite 210
Alexandra, VA 22314
www.abcop.org
2. The Board for Certification in Pedorthics (now merged into ABC) (Pedorthics)
Contact Person: Michelle Kimbrough
2025 Woodlane Drive
St. Paul, MN 55125-2998
info@cpeds.org
3. Board of Orthotist/Prosthetist Certification (All O&P)
Contact Person: Jim Newberry/Trisha Tatam
7150 Columbia Gateway Dr., Suite G
Columbia, MD 21045
www.bocusa.org
4. The Compliance Team, Inc. (All O&P)
Contact Person: Sandra Canally R.N., President
P.O.Box 160
905 Sheble Lane, Suite 102
Spring House, PA 19477
www.exemplaryprovider.com
5. JCAHO (All O&P)
Contact Person: Patricia Kurtz
601 13th Street, NW
Suite 1150N
Washington, D.C. 20005
http://www.jointcommission.org/
6. The National Board of Accreditation for Orthotic Suppliers (All O&P)
Contact Person: Chris Blake
1337 Howe Ave., Suite 230
Sacramento, CA 95825
www.nbaos.org
7. CARF International (All O&P)
Contact Person: Cindy L. Johnson, CPA
Chief Resource & Strategic Development Officer
4891 E. Grant Road
Tucson, AZ 85712
www.carf.org
8. Community Health Accreditation Program (All O&P)
Contact Person: Terry A. Duncombe, President & CEO
1300 19th Street, NW
Suite 150
Washington, DC 20036
http://www.chapinc.org
9. National Association of Boards of Pharmacy (approved for non-custom O&P)
Contact Person: Carmen A. Catizone
6701 Democracy Boulevard, Suite 300
Bethesda, MD 20817
www.nabp.net
10. HealthCare Quality Association on Accreditation (Custom Orthotics)
Contact Person: Mary K. Nicholas
Executive Director
PO Box 1946
217 West 4th Street
Waterloo, IA 50702
http://www.hqaa.org/
11. Accreditation Commission for Health Care, Inc. (Custom Orthotics)
Contact Person: Sherry Hedrick, RN, BSN, MPH
Director of Clinical Compliance and Accreditation
4700 Falls of Neuse Road, Suite 280
Raleigh, NC 27609
http://www.achc.org/