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  • Speak Out on Proposed Orthotics and Prosthetics Rule: Here's How

    A proposed rule from the Centers for Medicare and Medicaid Services (CMS) is drawing criticism from physical therapists (PTs) over additional requirements that PTs would need to meet to qualify as providers of custom orthoses and prostheses—and APTA is making it easy for members to let CMS know what they think.

    As reported by PT in Motion News in January, the proposed rule is meant to tighten up requirements around who CMS will work with when it comes to making and furnishing a wide range of devices. For PTs, the most notable parts of the proposed rule involve a requirement that providers must be "licensed by the state [as a qualified provider of prosthetics and custom orthotics], or … certified by the American Board for Certification in Orthotics and Prosthetics … or by the Board for Orthotist/Prosthetist Certification." The additional administrative and financial burdens could affect thousands of PTs across the country.

    APTA will provide CMS with comments on the proposed rule before the March 13 deadline. In the meantime, the association is urging members to get details on the proposal via an APTA fact sheet on the rule, and to make their individual voices heard by providing comments to CMS. APTA has created a member-protected template letter and instructions that make it easy for members to let CMS know why the proposal would increase costs and restrict patient access to PTs already qualified to provide custom devices. The template may be downloaded and shared with colleagues who also may be affected by the proposed rule.

    Comments

    • the regulations regarding DME and assist devices are already unnecessarily burdensome to primary care physicians. We should be empowering allied health professionals such as physical therapists rather than restricting further. I have seen much evidence of custom orthotics/prostheses causing unnecessary health care costs or bring dispensed unsafely. Sounds like CMS would prefer to pay for hospitalizations for unnecessary falls and foot ulcer infections rather than supporting prevention

      Posted by Kapono Chong-Hanssen on 2/27/2017 10:14 PM

    • Most of orthotics and prosthetics devices in the market today needs major improvement. The only way to enhance this innovation in product is to make accessibility and prescription easy. Right now the process of getting reimbursement for these devices is really difficult unattractive any additional provision would completely strained patient care and innovation.

      Posted by Olu Osunsanmi on 2/28/2017 12:52 PM

    • Will this have any implications for therapists who are performing serial casting? Reimbursement for this much needed service is already tough.

      Posted by Margie Mizera, PT, PCS on 2/28/2017 1:32 PM

    • The scientists of movement are among THE most well-prepared to prescribe, fabricate, and modify orthoses. Who else can look at alignment, balance, strength, endurance, flexibility and tissue integrity while considering the WHOLE person IN FUNCTION? No one. PTs can and should continue to create custom-molded orthotics.

      Posted by Mike Studer on 3/1/2017 12:50 AM

    • We should have a CMS Action Center function that parallels the current Legislative Action Center....doing a letter is slow for the March 13 deadline in this particular issue.

      Posted by George O'Malley -> EGPb on 3/1/2017 11:53 AM

    • We are the only facility in a 120 mile radius that sees Medicaid or Medicare. If this rule goes through, the access to fittings and fabrication "qualified" individuals would drop significantly and all Medicaid patients would be seen by one or two local individuals who choose to not accept those insurances at this time. Patients would lose their access.

      Posted by Daphne Ryan on 3/1/2017 1:20 PM

    • As a pediatric specialist in a rural area, my patients have one choice for orthotics provided by an O&P company. The company's fees are double what I bill snd I can deliver in two weeks versus 4-6 weeks. Also the patient's family is pressured to return every six months for another set of braces because that is when they are deemed eligible, even though they may not require another set that soon. Oftentimes the O&P braces are not appropriate because the MD doesn't know what to order so that leaves the choice to the orthotist, who knows nothing about the child's function or goals for mobility. It is in the best interest of the pediatric population to have PTs cast, fit, deliver and modify orthotics. This will ultimately save CMS money and be less burdensome on families.

      Posted by Christine Taylor on 3/1/2017 8:09 PM

    • Submitted comments via the regulations.gov website. Take the time to do it - easy to do and does not take long!

      Posted by Daniel Curtis -> >JW[<H on 3/2/2017 1:36 AM

    • We as PT's are trained in the proper prescription, application, and modification of orthotics and prosthetics to fit a patient’s needs. Adding additional requirements that prohibit these actions can be detrimental to patient care, especially in the Medicare and Medicaid population. Without the availability of these devices, an increase in the risk of falls, as well as further development of musculoskeletal asymmetries can develop and further decrease the prognosis of our patients. Another pertinent barrier consists within a patient's monetary realm. Patient's may not have the funds to pay other co-payments required for orthotists and prosthetist to primarily prescribe these devices and therefore will not receive the device that can be essential within their plan of care.

      Posted by Jason Berlongieri -> CHVc?F on 3/2/2017 11:17 AM

    • The advantage I see with a stronger licensing requirement is a protection from P&O techs fabricating braces for the kids I see (who often get poor quality orthotics because the P&O isn't supervising closely enough).

      Posted by Jody Mahoney on 3/2/2017 1:38 PM

    • Often we are fabricating for an acute injury such as a flexor tendon. The orthosis is fabricated based on specific requirements and correlate with the therapy. The therapist needs to be able alter or adjust depending on the progress/change. The orthosis is part of the therapy, not just a device used for protection.

      Posted by Julie Teal, OTR CHT on 3/2/2017 5:15 PM

    • Since there is no evidence that Physical Therapist fabrication, or provision and charging for orthoses is unsafe, or more expensive. It appears that this proposed rule is motived by political and financial motives rather than safety. It will limit access in many areas. Are podiatrists and chiropractors and orthopaedists also going to be restricted in the same way, since therapists have a stronger academic background to provide these services and devices than any of them. The cast for an orthosis is the prescription. Any orthotist should admit that this is true. A brace is only as good as the cast. When I cast for orthoses, I am taking my full evaluation of the patient into consideration. Orthotists are not trained to do this. This rule is unnecessarily and unfairly restrictive and it will result in worse care for our patients.

      Posted by Lisa Selby-Silverstein on 3/6/2017 9:40 AM

    • Please sent these to cms!!!

      Posted by Lisa Selby-Silverstein -> =NU[= on 3/6/2017 9:46 AM

    • Physical Therapists constantly evaluate and treat our patients with respect to their full biomechanical picture and its impact on the patient's chief complaint. We are constantly evaluating the function of the foot and the need for shoe modification and orthotic intervention. To limit our ability to intervene fully with the use of custom fitted devices would clearly compromise our ability to provide cost effective and timely care for our patients.

      Posted by Dr. John Sallade on 3/7/2017 8:07 AM

    • Physical therapists are fully trained to do a head to toe evaluation on a patient. We are movement specialists and truly know how to make shoe modifications or orthotic intervention. Our patients deserve to have easy accessibility to these devices through their physical therapist. We don’t prescribe orthotics without considering the whole patient. We evaluate the patient before and after the orthotic intervention to promote overall function. Prohibiting physical therapists from providing this service to their patients will burden the patient by increasing costs and increasing time spent with health care practitioners .

      Posted by Shayna Montello on 3/8/2017 11:02 AM

    • The requirement for PTs to be licensed to provide prosthesis and custom orthotics will create a large burden to patients, as this will limit availability and access to these devices. Patients may also be receiving physical therapy services simultaneously therefore the PT fitting and providing the device increases accuracy and function of the orthotic or prosthesis. PTs are experts in normal human locomotion and the gait cycle while knowing how to limit the amount of energy expended. As we know, patients with a prosthetic device expend about two times the amount of energy as those without a prosthesis and thus limiting energy expenditure is extremely important. Therefore, PTs are the most appropriate health care professionals to provide these devices to patients who need them to function safely and efficiently in their daily lives.

      Posted by Taylor Powell on 3/8/2017 11:53 AM

    • Implementing these additional requirements could potentially put patients at a great disadvantage. This would require extra time and money for the patient to make an additional appointment with another health care practitioner in order to get the prosthetic or orthotic device they need. PTs are seen as movement specialists and understand the biomechanics of the body. We have the knowledge to evaluate a patient's limitations and understand what the patient needs in order to achieve their functional goals through the prescription of a prosthetic or orthotic device.

      Posted by Emily Ramel on 3/8/2017 11:50 PM

    • This proposed rule change will greatly decrease accessibility to appropriate orthotic devices for many patients. Physical therapists are trained to provide comprehensive examinations of a patient's musculoskeletal, neurological, cardiopulmonary and integumentary systems and to thoroughly assess and evaluate a patient's movement during transfers as well as gait to develop and implement an appropriate orthotic intervention. We are also trained in fitting and modification of orthotics as needed. There is no current system that will allow PTs to obtain the needed certification to provide orthotics under this rule and the end result will be a significant lack of accessibility to providers of orthotics for patients.

      Posted by Sally Le Cras -> =GSc=K on 3/11/2017 2:40 PM

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