Virtual Advocacy Offers O&P Community New Tools to Advance Legislation


The COVID-19 pandemic’s lasting effects will be felt world-wide and its impact on Washington advocacy is no exception.  Flying to Washington to walk the halls of Congress will return over time as the primary way to impact legislators, but virtual advocacy, in some form, is here to stay and it offers the O&P community new tools to achieve its legislative objectives.  We urge practitioners and patients alike to go to and access the “Congressional Action Center” to connect with your representatives.  You should feel empowered to directly seek a videoconference with your Member of Congress or staff to promote two important bills:

  1. Medicare Orthotics and Prosthetics Patient-Centered Care Act (H.R 1990)

Representatives Mike Thompson (D-CA), GT Thompson (R-PA), GK Butterfield (D-NC), and Brett Guthrie (R-KY) have re-introduced this bipartisan bill in the House.  A Senate companion bill is expected to be re-introduced in early June.  NAAOP strongly supports this legislation and we need to demonstrate support for this bill by adding Congressional cosponsors to it. The bill is identical to the House version of the bill (H.R. 5262) introduced last year, which means we can build on the awareness and support for the bill from the previous Congress.

The bill would accomplish four key priorities for the orthotic and prosthetic profession: (1) Distinguish durable medical equipment (DME) from clinical, service-oriented O&P care in the Medicare statute and regulations, (2)  Limit the definition of “off-the-shelf” (or “OTS”) orthotics to devices that truly require only “minimal self-adjustment” by the beneficiary him- or herself, (3) Ban drop-shipping to patients’ homes of custom fit and custom fabricated orthoses and prostheses to prevent fraud and abuse and ensure patient access to clinical O&P care, and (4) Exempt licensed and certified O&P practitioners from OTS competitive bidding, treating them similarly to physicians and therapists by allowing them to provide OTS orthoses to their patients—without a contract—at the competitive bidding rate (not the higher fee schedule amount).

  1. “Triple A” Study Act (S. 1089 and H.R. 2461)

Senators Tammy Duckworth (D-IL) and Marsha Blackburn (R-TN) and Representatives G.K. Butterfield (D-NC-01) and Brett Guthrie (R-KY-02) recently introduced the Access to Assistive Technology and Devices for Americans Study Act, known as the “Triple A” Study Act.  This bill is identical to the Senate (S. 4343) and House (H.R. 8581) versions of the bills introduced last year, which means we can build on the awareness and support for the bill from the previous Congress.  The bill would direct the Government Accountability Office (“GAO”) to craft a report evaluating appropriate coverage and provision of health care services to people with limb loss or limb difference, including access to care, policies for matching specific devices to individual needs, affordability, and more. In addition, it would create an “apples to apples” comparison of coverage policies and usage across different payers, including Medicare, the Veterans Health Administration, and the commercial insurance market.

We urge all NAAOP members and friends to contact their legislators and ask them to cosponsor both of these important bills.  Thank you for your advocacy on behalf of the O&P profession.

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NAAOP and Range of Motion Project celebrate Limb Loss Awareness Month

NAAOP is proud to partner with the Range of Motion Project (ROMP) for Limb Loss Awareness Month as part of their national component collection drive.


Launching in April, and continuing throughout this spring, ROMP is collecting new and gently used prosthetic components from clinics, manufacturers, and individuals throughout the United States to ensure ROMP’s clinics in Guatemala and Ecuador can continue to provide high-quality prosthetic care to access-limited people with amputation. This is part of ROMP’s Components for a Cause (C4C) year-round component recycling program.


Nicole Ver Kuilen, NAAOP’s Inaugural Fellow and Consumer Vice President, is helping to lead this effort with ROMP. Ver Kuilen shared, “April is Limb Loss Awareness Month and it’s critical we acknowledge the fact that 9 out of 10 amputees worldwide do not have access to prosthetic care. This month, we can do something about that.” 


ROMP will cover the cost of shipping and donated components will go directly to use in changing someone’s life. It’s as simple as signing up and requesting a free shipping label! Recently, ROMP implemented a QR code tracking system to increase transparency and impact. Every knee, foot, and liner donated is tracked all the way to the patient, so donors know exactly who they’ve helped become mobile.


“What better way to help those with limb loss during this important month for the O&P community than through this project that our first Fellow is working on. NAAOP and our Board of Directors congratulate every organization and individual involved in making the lives better for those with limb loss worldwide,” shared George Breece, Executive Director of NAAOP.


ROMP now has over 150 clinic partners in the United States who have joined the movement for equitable access to prosthetic care. This represents just 5% of clinics nationwide, which is why ROMP is calling for hundreds more to join in the effort. In 2020, ROMP collected over 5,000 pounds of components and hopes to collect 7,000 pounds in 2021. 


Dave Krupa, CPO and ROMP Executive Director and Co-Founder shared, “Since 2005, ROMP has been working with the most marginalized individuals in the Americas who would otherwise not have access to prosthetic care. We are proud to share that we just surpassed our 4,000th prosthesis delivered in 2021. This journey would not be possible without ROMP’s C4C donors and partners like NAAOP who are dedicated to breaking down economic and systemic barriers that keep individuals from obtaining the freedom that comes from mobility. We believe in mobility for all.”



The National Association for the Advancement of Orthotics and Prosthetics is a non-profit trade association dedicated to educating the public and promoting public policy that is in the interest of the O&P patient. Since 1987, NAAOP has shaped positive results in healthcare legislation and regulation through strong government relations advocacy and education of policymakers. NAAOP serves the profession by representing and partnering with only those providers of orthotic and prosthetic services who truly believe that the patient must come first. For more information please visit:


About ROMP

The Range of Motion Project is a global, non-profit organization dedicated to improving the mobility of people with amputation. ROMP realizes its mission by providing high-quality prosthetic care, follow up services, community-based rehabilitation, and product innovation through its permanent operations. Since 2005, ROMP has delivered over 4,000 custom-made, high-quality prosthetic devices in Guatemala, Ecuador, and the U.S., and conducted over 10,000 patient visits. In the next 5 years ROMP plans to raise $5 million dollars to deliver 5,000 prosthetic devices to those in need. To learn more or help advance their mission, please visit


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House Introduces Medicare O&P Patient Centered Care Act!

Representatives Mike Thompson (D-CA), GT Thompson (R-PA), GK Butterfield (D-NC), and Brett Guthrie (R-KY) have re-introduced the bipartisan Medicare Orthotics and Prosthetics Patient-Centered Care Act (H.R 1990).  NAAOP strongly supports this legislation along with the organization that took the lead on introduction of this legislation, AOPA, as well as the other members of the O&P Alliance.

The bill is identical to the House version of the bill (H.R. 5262) introduced last year, which means we can build on the awareness and support for the bill from the previous Congress.  The bill would accomplish four key priorities for the orthotic and prosthetic profession.  It would:

  • Distinguish durable medical equipment (DME) from clinical, service-oriented O&P care in the Medicare statute and regulations, leading to recognition of the clinical care O&P practitioners provide.


  • Limit the definition of “off-the-shelf” (or “OTS”) orthotics to devices that truly require only “minimal self-adjustment” by the beneficiary him- or herself. This would help ensure that patients continue to have access to the clinical orthotic services they need.


  • Ban drop-shipping to patients’ homes of custom fit and custom fabricated orthoses and prostheses to prevent fraud and abuse and ensure patient access to clinical O&P care, and


  • Exempt licensed and certified O&P practitioners from OTS competitive bidding, treating them similarly to physicians and therapists by allowing them to provide OTS orthoses to their patients—without a contract—at the competitive bidding rate (not the higher fee schedule amount).

Now we need your help to build support for this legislation.  Please visit NAAOP’s website and access our action page to easily email your Representatives and ask them to cosponsor this bill simply by filling in your contact information and selecting your Representative to send the message to. If you can customize your message to discuss how this bill impacts you, all the better.

Thank you for your continued support of NAAOP and policies to advance the O&P profession!



  • Written by opie-admin

Harassment Education – Request for Feedback


The Alliance Subcommittee on Sexual Harassment has worked hard to combat sexual harassment in the O&P field. We are eager to hear your feedback as we plan our programs for 2021. Please click here and participate in the short survey that should take less than 5 minutes to complete




  • Written by opie-admin

New Congress and Administration Get Started


Election Impact:  The January run-off elections in Georgia flipped control of the U.S. Senate to Democratic control, propelling Senator Chuck Schumer to Majority Leader and casting Vice President Harris as the vote that will likely break many ties in the next two years.  This unlikely result means Democrats control the House, Senate and Executive Branch, with Joe Biden being sworn into the Presidency on January 20th.  Razor thin margins in both the House and Senate spells difficulty for progressive policies like Medicare for All, creation of a public insurance option, and even lowering the Medicare age to 60 years old.  Bipartisanship will be at a premium, but with a budget process known as “reconciliation,” which requires only 51 votes in the Senate to pass certain legislation, there is still a lot of opportunity to achieve O&P objectives.  And the Biden Administration is showing signs of being very active on health policy, which does not require Congress’ approval.


O&P Legislation:  With all of the key House and Senate champions of the Medicare O&P Patient-Centered Care Act returning to Congress, quick reintroduction is expected in the coming months.  The bill would separate DME from O&P, reform the definition of off-the-shelf (OTS) orthotics, exempt licensed and certified orthotists and prosthetists from competitive bidding, and ban drop shipping of custom O&P to patients’ homes.  The bill will continue to compete with COVID-19 relief legislation which will take most of the oxygen out of the Congressional agenda, but legislative vehicles on which to attach this bill will be available later this year and next.  In addition, the “Triple A” Study Act, which would dramatically improve the data the profession has on O&P prevalence, use, and insurance coverage, is also expected to be introduced in the coming months.  NAAOP supports both of these bills and urges our members to request their Members of Congress to become cosponsors of the bills.


DMEPOS Proposed Rule:  In the closing days of the Trump Administration, CMS collected comments on its CY 2021 Proposed Rule on Durable Medical Equipment, Prosthetics, Orthotics, and Supplies, but did not have time to issue a final rule.  There were several important proposals in this year’s rule—which is currently on hold until the Biden Administration decides how it wants to proceed.  Of particular note in the proposed rule are the improvements to the HCPCS coding and pricing processes, including the way CMS determines the benefit category of new technologies.  NAAOP will be closely monitoring this rule and will report new developments to the NAAOP membership.


Veterans Administration Final Rule on Prosthetics:  In late December, the VA finally issued its final rule on prosthetics, clarifying that veterans do, in fact, have a role in deciding which practitioner will be able to provide their care.  But the final rule still grants the VA authority to make this determination.  Since NAAOP spearheaded the Injured and Amputee Veterans Bill of Rights, NAAOP has made veteran choice of practitioner a top priority.  For this reason, NAAOP will continue to closely monitor this situation and will intervene further if necessary.

Sexual Harassment:  Maggie Baumer, J.D., President-Elect of NAAOP, has been chairing an O&P Alliance Subcommittee on Sexual Harassment.  Look for the NAAOP video coming soon that will feature Maggie as she reports on the status of this important initiative and seeks further engagement in this issue across the O&P profession.

  • Written by opie-admin

NAAOP Hosts Virtual Congressional Fly-In to Advocate for O&P Legislation

On December 8, 2021, NAAOP hosted a Congressional “Fly-In” to advocate for passage of orthotic and prosthetic legislative priorities. The event was virtual and designed as a “pilot” to assess the feasibility of conducting such events in the future. The pandemic has made telephonic visits to Capitol Hill offices much more common, and this enabled NAAOP to proceed with this event. Over twenty board members, NAAOP fellows, and members in key Congressional districts participated in over 30 meetings with Congressional leaders. The timing of this advocacy event could not have been better, with Congress poised to pass a massive, year-end spending bill to fund the federal government and debating a major COVID-19 relief package. These pieces of legislation are considered “must-pass” which presents an opportunity to attach O&P-specific bills to this legislative vehicle.

NAAOP focused on three issues, passage of the Medicare O&P Patient-Centered Care Act, passage of the “Triple A” Study Act, and introduction to a new issue, the importance of recognizing the medical necessity of prosthetic limbs and other technologies to enable people with disabilities to exercise and remain fit and healthy. NAAOP members and friends who wish to help advocate for passage of the two bills can go to the Legislative Action Center on the NAAOP website at

In virtually all of our Congressional meetings, the three issues we discussed were well received and there is reason to be optimistic for action on this legislation in the future. However, these bills are not necessarily considered linked to COVID-19 and, therefore, not necessary to include in the end-of-year packages. There are so many pressing matters before Congress that several champions of our legislation cautioned that inclusion of our provisions in year-end bills would be a huge lift, notwithstanding their support for the contents of our proposals.

The Patient-Centered Care Act is bipartisan and has champions on both sides of Congress. A Congressional Budget Office estimate of its cost is not yet complete and this is a necessary step for Congress to proceed. If action is not taken this year to advance that bill, AOPA has learned—and the lead sponsors NAAOP met with confirmed—that this legislation will be re-introduced in the new Congress. The Triple A Study Act was introduced in August 2020 at the behest of the Amputee Coalition. Our advocacy centered around building awareness of and support for the legislation and the value of obtaining the wealth of information on O&P insurance coverage, demographics, and access to care the bill would produce. NAAOP also highlighted a position statement and policy paper from Nicole Ver Kuilen, NAAOP board member and Inaugural NAAOP Fellow, on the right of people with disabilities to exercise. The issue received broad support and encouragement to return to the next Congress to discuss further.

NAAOP would like to thank all of those who participated in this successful advocacy event on behalf of the O&P profession and the patients we serve.

  • Written by opie-admin

Election Results Set Stage for Health Care Policy Changes

2020 Election: President-Elect Biden’s win in the 2020 election was muted by weeks of controversy over vote counts and legal challenges but the transition to a Biden Administration is now underway. The expected “blue wave” did not materialize as some expected, with Democrats losing several seats in the House, making the 117th Congress one of the slimmest Democratic margins in recent memory. Senate Republicans lost one seat and retain control of that chamber to date, but two runoff elections scheduled for January 5th in Georgia will determine whether Republicans or Democrats control the Senate. If Democrats win both seats, an unlikely prospect, Democrats will be able to pass budget legislation with a simple 51-vote majority, but most legislation will still require bipartisan cooperation to prevent a 60-vote Senate filibuster. Either way, the mixed results place tremendous emphasis on the need for bipartisan cooperation.

Prior Authorization: Prior authorization of six lower limb prosthetic HCPCS codes will be implemented nationwide on December 1, 2020 as the four-state pilot program, which began September 1st, is expanded. By all accounts, the program has been more successful than expected, with relatively quick prior authorization approval times. The upside of prior authorization is that claims for payment are afforded some degree of finality, with less risk that such claims will be audited by Medicare contractors and the funds recouped. If you experience problems with the nationwide rollout of prior authorization, please report your experiences to NAAOP and ask your patients to call 1-800-Medicare to lodge a complaint with the program.

OTS Competitive Bidding: The Medicare program is pressing forward with implementation of competitive bidding of certain off-the-shelf (“OTS”) orthotics in 127 competitive bidding areas (“CBAs”) throughout the United States on January 1, 2021. Despite requests to delay the program due to the pandemic and the lack of sufficient notice to providers, CMS is rolling out the program which applies to 23 HCPCS codes for OTS knee and back braces. The program was able to achieve, on average, 30% to 35% reductions in reimbursement amounts, varying by geography. According to Medicare data, certified and/or licensed orthotists provide less than 20% of these orthoses, with physicians, therapists, DME suppliers and pharmacies providing the bulk of these orthoses. Claims submitted for these 23 OTS codes will not be paid if the supplier does not have a competitive bidding contract.

NAAOP Virtual Congressional Fly-In: NAAOP is hosting a “pilot” virtual Congressional Fly-In to promote passage of O&P legislation including the Medicare O&P Patient-Centered Care Act (S.4503) and the Triple A Study Act (S. 4343). The Fly-In is a pilot to test the effectiveness of a virtual model as Congressional members and staff adapt to advocacy during a pandemic. Over 20 board members, NAAOP Fellows, and key NAAOP members will participate in over 50 telephonic meetings on December 8, 2020. NAAOP will assess the effectiveness of this model and decide whether to host these fly-ins in the future.

Thanksgiving: It has been a very difficult year by all accounts, but NAAOP is optimistic that better days lie ahead. We at NAAOP take this opportunity to wish all NAAOP members and friends a Happy Thanksgiving in the safest and most meaningful way possible. And, as always, we thank you for your membership and support!

  • Written by opie-admin

Health Care on the Ballot as America Votes

Health care is playing an outsized role as the 2020 election is underway and the Senate is poised to install a 6-3 conservative majority days before the U.S. Supreme Court hears arguments about the Constitutionality of the Affordable Care Act (ACA).

President Trump and former Vice President Biden face off on November 3rd but the election is already well underway.  At the time of this writing, early 18 million people have already voted in states that permit early voting.  Turnout is expected to break records.  One of the dominant campaign themes has been health care including the national response to the pandemic and the threat to health care access through challenges to the Affordable Care Act.

The Biden Campaign offers extensive detail on health care policy, including reducing the age to 60 (from 65) for individuals eligible to join the Medicare program, establishment of a “public option” for the uninsured to obtain health insurance in order to drive down the cost of health care while enhancing access, bolstering existing aspects of the ACA, reducing the cost of prescription drugs, and coordination of a national plan to combat the pandemic.

The Trump Campaign did not issue a policy platform this year so details of what a second Trump term would mean for health care policy is not entirely clear.  But it is likely the next four years would include continued efforts to reduce the price of prescription drugs, limit “surprise” medical bills, provide greater transparency in health care pricing, and implement additional reductions in regulatory burdens on health care providers.  Although the President professes strong support for protecting people with pre-existing conditions, his Administration is poised to argue before the Supreme Court that the ACA is invalid and should be entirely struck down.

An accelerated effort to replace Justice Ruth Bader Ginsburg with Judge Amy Coney Barrett is being driven, in part, by a desire to fill this court vacancy before the election and have a full court in place to hear the latest legal challenge to the ACA.  A lower Texas court determined that the ACA is invalid because Congress eliminated the monetary penalty for failure to satisfy the individual insurance mandate that is critical to achieving near universal coverage, which accompanies protections from pre-existing conditions, community rating, non-discrimination based on health status, protection from lifetime and annual caps, and other provisions.  If there is no monetary penalty for failing to have insurance, the Texas court argued, then Congress’ authority to pass the ACA based on its taxing power is invalid.  The lower court struck down the entire 1100-page law but the result was “stayed” until the Supreme Court could hear the case.

That case is scheduled for argument on November 10, 2020 and a decision will be rendered sometime in June of 2021.  At stake are numerous insurance protections cited above that impact millions of Americans, as well as health care coverage for 20 million people from expanded Medicaid and private insurance under the health insurance exchanges.  Despite the expected conservative majority hearing the case, there is a real chance the court will not strike down the entire ACA.  The real question before the court is whether the individual mandate can be severed from the existing law while the rest of the law survives.  This is the most likely outcome, but there are no guarantees with any case before the highest court.  NAAOP will continue to keep our members and friends informed as developments occur.

We urge all members of the O&P profession to VOTE on November 3rd!

  • Written by NAAOP

Major Bills Introduced and Policies Advanced as COVID-19 Drags On

Significant developments occurred over the past several weeks impacting the orthotics and prosthetics community including the following:

  • Introduction of Senate Bill 4503: Senators Daines (R-MT), Warner (D-VA), Cassidy (R-LA), Duckworth (D-IL), and Cornyn (R-TX) and introduced S. 4503, a companion bill to H.R. 5262, the Medicare O&P Patient-Centered Care Act of 2020.  This long-awaited legislation is bipartisan, mirrors the House version of the bill, and provides the O&P community with a legislative goal in the Senate. S. 4503 separates DME from O&P clinical services, reinstates Congressional intent on the meaning of off-the-shelf (OTS) orthotics for purposes of competitive bidding, exempts certified and licensed orthotists and prosthetists from OTS competitive bidding, and prohibits “drop shipping” to patients homes of any orthoses or prostheses that require clinical services. NAAOP supports this legislation and encourages our members and friends to write your Senators seeking cosponsorship of the bill by clicking on
  • S. 4343; The Triple A Study Act: The Amputee Coalition of America recently announced introduction of the Triple A Study Act, bipartisan legislation sponsored by Senators Blackburn (R-TN) and Duckworth (D-IL) that would collect nationwide data on limb loss and limb difference and update our collective knowledge base of the patients served by the O&P profession. NAAOP supports this legislation and will be advocating for its passage.
  • Medicare Audits and Prior Authorization: Having suspended Medicare audits and implementation of prior authorization for six lower limb prosthetic codes due to COVID-19, CMS has now reengaged these programs. As of August 3, 2020, Medicare contractors are permitted to begin audits of Medicare providers and suppliers but have been instructed by CMS to accommodate those providers overwhelmed by COVID response. CMS is also pursuing prior authorization of six lower limb prosthetic codes beginning September 1st in four states (i.e., TX, CA, MI, and PA) and will implement the program nationally on December 1st. In addition, lower limb prosthetic components described by these six codes must be verified by the PDAC by January 1st. For more information on the prior authorization program, Noridian will be hosting a webinar on September 10th at 12:00 Noon, Central Time.  Click here to sign up for this webinar.
  • OIG Orthotics Reports Continue to Alarm the O&P Community: In the past several weeks, three separate HHS Office of Inspector General (OIG) reports have been issued on suppliers of orthotics, asserting very high error rates, in some instances 100% of the claims reviewed. The suppliers under review typically employ a business model reliant upon drop shipping certain typically off-the-shelf orthoses directly to patients’ homes. The OIG asserts that a simple physician prescription is not enough to justify medical necessity and that suppliers are obligated to verify the medical necessity of the orthoses they bill to the Medicare program. These reports reflect negatively upon the orthotics community, but they also provide evidence of the need for Congress to pass the Medicare O&P Patient-Centered Care Act and are helpful in making that case to legislators.
  • Nicole Ver Kuilen Just Felt Live Running: Nicole Ver Kuilen, the NAAOP Inaugural Fellow and one of our newest NAAOP board members, announced on July 20th, in conjunction with the 30th Anniversary of the Americans with Disabilities Act, a virtual race to be held on October 3rd across the country to promote exercise among people with disabilities.  The race is being organized by Nicole’s organization, Forest Stump, and is designed to highlight the discriminatory effect of coverage denials by insurance companies of prosthetics, orthotics, and assistive devices and technologies that allow people with disabilities to be physically fit and active.  The virtual race will culminate in Washington, D.C. with the delivery to Congress of a petition to make this point.  To support this incredible effort, please click on the following link.  Congratulations Nicole on this innovative advocacy project! NAAOP is with you all the way!

  • Written by Web Updates

Major Medicare and VA Developments Impact O&P Care

As the Trump Administration continues to grapple with the rising number of COVID-19 cases across the nation, the Centers for Medicare and Medicaid Services (“CMS”) and the Veterans Health Administration (“VHA”) recently announced policy developments that impact the provision and reimbursement of orthotic and prosthetic care.


CMS Moves Forward with Prior Authorization for Six Lower Limb Prosthetic Codes


On July 1, 2020, CMS announced that it will require prior authorization for six lower limb prosthetic Healthcare Common Procedure Coding System (“HCPCS”) codes (L5856, L5857, L5858, L5973, L5980, and L5987) with dates of service on or after September 1, 2020, in four states—Texas, Pennsylvania, Michigan, and California.  CMS will then expand prior authorization nationwide beginning on December 1, 2020.  Prior to the COVID-19 public health emergency, CMS stated that the six lower limb prosthetic HCPCS codes would be subject to prior authorization as a Medicare condition of payment in these same four states beginning May 11, 2020, and nationwide beginning October 8, 2020.


In addition, on June 26, 2020, the Durable Medical Equipment Medicare Administrative Contractors (“DME MACs”) and the Pricing, Data Analysis, and Coding Contractor (“PDAC”) published a joint announcement and a revised Lower Limb Prostheses Local Coverage Article announcing that claims will not be paid for these six prosthetic codes with dates of service on or after January 1, 2021 unless the particular prosthetic component has undergone code verification by the PDAC and approval to bill a specific prosthetic L-code has been published on the appropriate Product Classification List.


NAAOP believes the circumstances that prompted CMS to delay prior authorization still exist and, in fact, have gotten worse.  NAAOP does not believe it is an appropriate time to impose new documentation requirements on health care providers and is taking steps to convey its position to CMS.


CMS to Resume Medicare Fee-for-Service Audits


On July 1, 2020, CMS also announced that medical review activities—including pre-payment audits conducted under the Targeted Probe and Educate program and post-payment audits—will resume beginning on August 3, 2020.  CMS previously suspended most Medicare Fee-for-Service medical reviews in light of the COVID-19 public health emergency.  CMS notes that providers selected for review should discuss with their DME MAC any COVID-19-related hardships they are experiencing that could affect audit response timeliness.


VHA Publishes Directive Regarding the Use of Not Otherwise Classified (“NOC”) Codes


On June 24, 2020, VHA released VHA Directive 1045 establishing the policy and responsibilities for developing and utilizing appropriate coding, market analyses, and contract guidance for prosthetic limbs and/or custom orthoses.  Among other things, VHA Directive 1045 confirms that the Department of Veterans Affairs (“VA”) may assign codes (i.e., miscellaneous “not otherwise classified” codes) to prosthetic limbs and custom orthoses, although the directive lacks details regarding the VA’s coding process.  NAAOP suspects that VHA published this directive in response to the Department of Veterans Affairs Office of Inspector General’s report entitled, “Veterans Health Administration: Use of Not Otherwise Classified Codes for Prosthetic Limb Components.”  A key conclusion of the directive is that the VA retains independent authority to code new technologies when CMS has not yet assigned—or does not intend to assign—a billing code.  This is a very positive development that NAAOP will pursue in the future.


NAAOP will continue to keep our members informed as regulatory developments continue.  Please consult our website for more information.


  • Written by NAAOP

National Association for the Advancement of Orthotics and Prosthetics (NAAOP)