In response to member requests, NAAOP has been working with the Orthotic and Prosthetic Alliance organizations over the past several weeks on a proposal for the Centers for Medicare and Medicaid Services (CMS) to authorize appropriately credentialed orthotists and prosthetists to submit claims for certain Medicare services furnished virtually (through telehealth) during the COVID-19 public health emergency. This initiative culminated in an O&P Alliance letter submitted to the Secretary of Health and Human Services (HHS), Alex Azar, as well as the CMS Administrator, Seema Verma, on June 11, 2020. A copy of the letter can be viewed here.
The letter states that in the case of senior and disabled Medicare beneficiaries who are at increased risk for COVID-19, “it is especially important that certified and/or licensed orthotists and prosthetists be able to assess, triage, and provide ongoing orthotic and prosthetic care to individuals who remain safely at home. Under normal circumstances, patients would simply visit their orthotist or prosthetist when they were experiencing problems with fit, comfort, or function of an orthotic brace or prosthetic limb. In a pandemic environment, the patient must weigh the prosthetic or orthotic problem against the risk of potential infection by visiting their orthotist or prosthetist in person.”
The letter makes the case that the COVID-19 pandemic has exposed an inequity in reimbursement of O&P clinical services that NAAOP and the Alliance believe should be rectified. The letter cites a number of clinical examples of services that are not reimbursable to appropriately credentialed orthotists and prosthetists outside of the 90-day window after delivery of an orthosis or prosthesis, but are separately reimbursable to physicians and therapists under the CPT coding system. Some of these clinical services include:
- Reinforcing the appropriate wearing schedule;
- Confirming the prosthesis or orthosis is being worn properly;
- Evaluating the function of the device;
- Assessing the need for any ancillary supplies;
- Addressing fitting problems based on a change in the patient’s condition; and,
- Observing any potential or actual skin breakdowns.
The COVID-19 pandemic has exposed this inequity and prompted NAAOP and the O&P Alliance to press forward with a request for CMS to authorize separate reimbursement of these clinical services through telehealth during the public health emergency. Utilizing telehealth would allow these elements of care to be accomplished without placing orthotic and prosthetic practitioners or patients at unnecessary risk of contracting the COVID-19 virus.
The letter recommends that CMS grant authority for appropriately credentialed practitioners to use either certain L codes or K codes to submit claims for these services, but is open to ongoing discussions with the agency to discuss alternatives in this regard. NAAOP and the Alliance organizations will continue to work with CMS to advance this issue and will report back to our membership as developments occur.