Tuesday, January 17, 2017 CMS Considers Upgraded Requirements for Orthotics and Prosthetics Providers A proposed new rule from the Centers for Medicare and Medicaid Services (CMS) would include qualified physical therapists (PTs) among the providers who could furnish and bill for custom orthotics and prosthetics; however, the CMS definition of "qualified" may have administrative and financial implications for PTs. The proposed rule, issued on January 11, aims to tighten up requirements around who CMS will work with when it comes to making and furnishing devices ranging from glass eyes to exoskeletal systems and finger orthotics. In addition to an estimated 900 PTs who could be affected by the proposed rule, the provisions would also have an impact on facilities including skilled nursing facilities (SNFs) and rehabilitation agencies. For PTs, the most notable parts of the proposed rule have to do with how a provider would become qualified to participate in the system. According to a fact sheet from CMS, while PTs are among the providers who could participate, they would need to 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." These requirements would need to be met within a year after CMS posts its final rule, or at the time of the provider's reaccreditation cycle, whichever is later. CMS is accepting comments on the proposed rule until March 13, 2017. APTA regulatory affairs staff is preparing comments to CMS and will post a fact sheet on the proposal in the coming weeks.