AOPA Submits Comments on the Inclusion of the Term “Orthotics and Prosthetics” in The Uniform Glossary of Medical Terms

Update:  Just 10 days after the March 28th deadline for submission of comments regarding the Uniform Glossary of Medical Terms, CMS finalized an update to the glossary that included the revision to the definition of the term “orthotics and prosthetics” that were suggested by both AOPA and the O&P Alliance.  Both groups suggested that the definition no longer include the term “due to breast cancer” when defining external breast prosthesis as part of the larger definition of the term “orthotics and prosthetics.”  AOPA is pleased that its suggested revision was considered and accepted by CMS and the other federal agencies tasked with maintain the Uniform Glossary of medical Terms.

AOPA recently submitted comments applauding the decision to include a separate and distinct definition of the term “Orthotics and Prosthetics” as part of the Uniform Glossary of Medical Terms.  This document, which was established through provisions of the Affordable Care Act, is intended to provide guidance to private insurance companies when defining and establishing coverage for essential health benefits.

Recently, the Department of Labor, in conjunction with the Centers for Medicare and Medicaid Services (CMS), requested public comment on the latest revision to the Uniform Glossary of Medical Terms, which, for the first time, included a proposed definition of the term Orthotics and Prosthetics.  The Uniform Glossary proposed the following definition, which matched the suggested definition that was submitted for consideration by AOPA and the O&P Alliance as part of their previous comments:

Leg, arm, back, and neck braces, and artificial legs, arms, and eyes, and external breast prostheses incident to mastectomy resulting from breast cancer. These services include: adjustments, repairs, and replacements required because of breakage, wear, loss, or a change in the patient’s physical condition. 

AOPA’s comments applauded the decision to include a separate definition of the term Orthotics and Prosthetics as part of the Uniform Glossary and suggested a minor change to eliminate the requirement of breast cancer as the sole cause for mastectomy in the definition of a breast prostheses.  AOPA’s suggested revision to the definition reads as follows:

Leg, arm, back, and neck braces, and artificial legs, arms, and eyes, and external breast prostheses incident to mastectomy. These services include: adjustments, repairs, and replacements required because of breakage, wear, loss, or a change in the patient’s physical condition.

AOPA and its partners, such as the O&P Alliance will continue to advocate for fair and equitable treatment of O&P providers.  The inclusion of the separate definition of the term orthotics and prosthetics in the Uniform Glossary provides additional distinction of O&P services from the universe of Durable Medical Equipment and represents a significant advancement in acknowledging the unique skill set that properly trained and educated O&P practitioners offer to patients.

AOPA’s comments may be viewed here.

Questions regarding this issue may be directed to Joe McTernan at jmcternan@aopanet.org or Devon Bernard at dbernard@aopanet.org.