Submit Comments on OTS Competitive Bidding & Ensure Proper Care for Your Patients

The Centers for Medicare and Medicaid Services (CMS) is soliciting comments on its proposed inclusion of off-the-shelf (OTS) spinal orthoses and OTS knee orthoses as product categories in the next round of Medicare competitive bidding. While the impact of inclusion of OTS spinal and knee orthoses will not be felt for at least two years, there is a current delay in the implementation of future rounds of competitive bidding until at least January 2021, the recent CMS announcement represents the first indication that OTS orthoses of any kind will be included in competitive bidding.

There are a total of 16 OTS spinal orthoses and 8 OTS knee orthoses that have been identified for inclusion in the competitive bidding program. AOPA has performed a preliminary analysis on the codes included in the proposal, and traditional O&P providers are responsible for less than 15% of overall claims submitted to Medicare for the codes in question.  While these codes do not represent a large portion of a typical O&P practices business, AOPA continues to believe that no orthoses should be subject to competitive bidding; especially considering the inappropriate expansion of the definition of OTS.

AOPA will be submitting comments to CMS indicating that competitive bidding for OTS orthoses is not in the best interest of patients or the Medicare program. Click here to submit pre-drafted comments to CMS via email. Comments must be submitted by midnight on December 17, 2018.

Questions regarding this issue may be directed to Joe McTernan at or Devon Bernard at