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Accreditation Requirements
AOPA strongly supports accreditation for O&P facilities, through the American Board for Certification in Orthotics, Prosthetics and Pedorthics (ABC) or the Board Of Certification/Accreditation, International (BOC). Click here to see AOPA's position on accreditation and certification. While at the present time the Medicare Program does not mandate accreditation, the Centers for Medicare and Medicaid Services (CMS) has indicated that it will at some point in the future, possibly as early as 2009.
A large part of the accreditation requirements for both ABC and BOC are the Medicare Quality Standards. Click here to see the latest version, dated October 2008.
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Exclude Orthotic Services from the SNF PPS
AOPA urges Congress to exclude orthotic services from the consolidated billing requirements of the Medicare Skilled Nursing Facility Prospective Payment System (SNF PPS) payment methodology. This legislative adjustment would permit orthotists to be reimbursed separately from the PPS rate, and paid according to the established Medicare Part B orthotic and prosthetic fee schedule for orthotic services provided in the SNF setting. Such a change can be made budget neutral by appropriately adjusting the SNF Resource Utilization Group (RUG) payments to account for the exclusion of orthotic services.
Click Here for full position
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Licensure
AOPA supports O&P licensure, through the enactment of well-crafted licensure bills. Below are two existing laws that may be used as a starting point for writing licensure legislation. If you use these as guides, you will need to modify it to your own state's requirements.
In addition, we have a provided links to various existing state licensure acts.
PROFESSIONS AND OCCUPATIONS (225 ILCS 84/) Orthotics, Prosthetics, and Pedorthics Practice Act
PROFESSIONS RELATED TO USE OF CERTAIN MEDICAL EQUIPMENT
Licensed States
Alabama - Board of Prosthetists and Orthotists (2002)
Arkansas - Board of Orthotics, Prosthetics & Pedorthics (2008)
Florida - Board of Orthotists and Prosthetists (2007)
Georgia - Composite Board of Medical Examiners (2006)
Illinois - Department of Professional Regulation Orthotics & Prosthetics Licensure (2000)
New Jersey - Orthotics & Prosthetics Board of Examiners (1991)
Ohio - State Board of Orthotics, Prosthetics, and Pedorthics (2000)
Oklahoma - Board of Medical Licensure (2001)
Rhode Island - Division of Health Professions and Regulation, Department of Health (2007)
Tennessee - Board of Podiatric Medical Examiners (2007)
Texas - Board of Orthotics & Prosthetics (1999)
Washington - State Department of Health (1997)
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Medicare Fee Schedule Updates
Medicare should assure the annual Medicare updates without freezes or reductions. The Medicare program pays for orthotic and prosthetic (O&P) services based on a pre-determined fee schedule. The fee schedule amount for O&P services is calculated using historical Medicare allowed amounts from 1986-1987 and is updated annually based on the Consumer Price Index (CPI). Since the Medicare O&P fee schedule was implemented in 1989, federal reimbursement rates for O&P services have increased only 35 percent while the CPI has increased by more than 66 percent.
Fee Schedule Payment Update with 2008 Projection
Alternative to Fee Schedule Reductions
Medicare O&P
Improvements to Reduce Fraud and Abuse
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O and P Parity
Orthotic and Prosthetic Parity Legislation Federal Campaign
Prosthetic Parity Act of 2008 State Bills
Alabama House
Alabama Senate
Connecticut
Iowa House
Iowa Senate
Kentucky
Maryland House
Maryland Senate
Michigan
Missouri
Nebraska
New York Assembly
New York Assembly
Oklahoma
Pennsylvania
Tennessee House
Tennessee Senate
Texas
Utah
Virginia State Laws
Colorado (2001)
Maine (2003)
New Hampshire (2004)
Rhode Island (2006)
Massachusetts (2006)
California (2006)
Oregon (2007)
New Jersey (2008)
Indiana (2008)
Vermont (2008)
Louisiana (2008)
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Qualified Provider Access to L Codes
The O&P Alliance supports the proposed use of quality standards and mandatory accreditation for the provision of all Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) items and services. These requirements were mandated by the Congress as part of the competitive bidding section of the Medicare Modernization Act of 2003 (MMA). It is through effective quality standards and accreditation that we believe CMS will improve the quality of O&P services provided to Medicare beneficiaries while vastly reducing opportunities for fraud and abuse.
Click here for position paper
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Separating O and P from DME
Because legislation continues to lump DME and O&P together, we believe there could potentially be inappropriate implications for the O&P field. The American Orthotic and Prosthetic Association therefore requests that any references to "orthotics and prosthetics" be deleted from provisions that deal specifically with DME and that O&P be treated and evaluated separately.
Click Here for position paper