US-POLITICS: Exclusion of Orthotic Services in HCFA Competitive Bidding Project
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US-POLITICS: Exclusion of Orthotic Services in HCFA Competitive Bidding Project
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Dear US OANDP-L Members:
This a repost attempt of my letter referenced in my previous post as it did
not post with the attached file. OANDP-L will no longer accept attached
files to the Listserver. You will therefor find my letter in body of this
post and if you would like it in its original WORD for Windows DOC file
format version just request it from me directly.
John N. Billock, CPO, Clinical Director
Orthotics & Prosthetics Rehabilitation Engineering Centre
700 Howland-Wilson Road, SE
Warren, Ohio 44484 USA
========================================================
March 6, 2000
The Honorable George Voinovich
U.S. Senate
317 Hart Senate Office Building
Washington, D.C. 20510
Re: Exclusion of Professional Orthotic or Prosthetic Healthcare Services in
HCFA Competitive Bidding Projects
Dear Senator Voinovich:
Enclosed you will find a copy of a letter I have sent to HCFA Administrator,
Nancy-Ann DeParle, regarding HCFA's plans to inappropriately include
professional Orthotic healthcare services in a competitive bidding
demonstration project.
On January 7, 2000, the Health Care Financing Administration (HCFA) published
a notice in the Federal Register requesting the Office of Management and
Budget (OMB) to conduct an emergency review by February 15, 2000, of the
eight bidding forms necessary to implement a second Medicare competitive
bidding demonstration project. Although a site for this demonstration
project has yet to be determined, HCFA announced in the notice that the
products to be offered for competitive bidding include oxygen equipment and
supplies, hospital beds, standardized orthotic products, manual wheelchairs,
and nebulizer drugs.
As a constituent who supported you in your election to the Senate, I am
writing to express my concerns on the above and to seek whatever support you
can offer to prevent this travesty from continuing further. Besides the
obvious quality of care issues conveyed in my letter to Ms. DeParle,
HCFA/Medicare reimbursement rates for professional orthotic and prosthetic
(O&P) healthcare services have been controlled by Medicare at an approximate
average of 1% per year over the past 15 years. Needless to say, O&P
healthcare costs have been well controlled, and in many cases are inadequate,
for the level of care required. Along with this fact, the HCFA/Medicare
reimbursement levels have become the national standard by which most, if not
all, private healthcare insurance carriers determine their usual and
customary O&P reimbursement levels. Again, based on this fact alone, one can
only conclude the cost of O&P is not excessive or inappropriate! Frankly,
there is an alarming number of professional O&P practitioners who are leaving
the profession as a result of the level that declining reimbursement rates
have reached.
During this same time, HCFA has all but ignored the obvious confusion of what
constitutes the provision of professional Orthotic and Prosthetic healthcare
services with the provision of durable medical equipment (DME) supplies. (To
clarify, the provision of professional O&P healthcare services involves both
clinical and technical services related to the evaluation, design and
development of custom fabricated and custom fit orthoses (orthopedic braces)
and prostheses (artificial limbs). The provision of DME supplies involves
the dispensing of manufactured devices and supplies such as crutches, canes,
hospital beds, wheelchairs, ostomy supplies, etc.) However, both providers
-- those of us who are qualified to provide professional O&P healthcare
services, as well as those providers who sell and/or rent DME supplies or
equipment -- have equal access to the same O&P L-codes, which are used for
billing purposes. This has obviously led to well-documented fraudulent
billings to Medicare by unscrupulous DME suppliers who are not qualified to
provide O&P healthcare services. This fraud and abuse by non-qualified
providers has been documented time after time, in report after report,
supporting and encouraging the need for provider qualifications to control
the ever-increasing fraudulent expenses to the Medicare system.
In 1997,the OIG issued a report entitled, Medicare Orthotics, which was
built on the findings of the 1994 Report referred to in my letter to Ms.
DeParle. This report clearly recommended the need for new provider standards
for professional O&P practitioners to limit access to the O&P L-codes to
qualified providers. This has not yet occurred, even after HCFA agreed with
this recommendation.
Because of HCFA's unwillingness to identify qualified O&P healthcare
providers and limit access to the O&P L-codes to these qualified providers,
the fraud and abuse by unqualified providers continues, as well as the
confusion between O&P services and DME supplies. Therefore, we, as qualified
providers of O&P services continue to inappropriately bear the brunt of
HCFA's efforts to control the non-legitimate use of the O&P billing codes by
the unqualified suppliers. Competitive bidding is now just one more example
of HCFA's misguided efforts to control this abuse
Also, HCFA's application of competitive bidding to general or standardized
orthotic products or devices is inappropriate because it undervalues the
critical service component of orthotic care. Despite repeated assurances
that HCFA would not use competitive bidding in the area of O & P, they now
clearly intend to do so!
Again, I am opposed to the inclusion of orthotics or prosthetics in any of
HCFA's competitive bidding demonstration projects for the primary reasons
stated in my letter to Ms. DeParle. In addition to my comments above and
those stated in the enclosed letter, competitive bidding eliminates the
beneficiary's choice of provider, which is imperative when the Medicare item
or service at issue is customized to the individual needs of a patient and
the clinical component of care is every bit as important as the O&P device
itself. More importantly, contracting with the lowest bidder will lead to a
race to the bottom and jeopardize the quality of the orthotic and/or
prosthetic devices and services. Competitive bidding would also adversely
affect O&P services, which require high levels of training, technology,
materials and a clinical environment. In addition to interrupting
long-standing relationships between patients and providers, competitive
bidding is particularly inappropriate for customized services and devices
such as O & P.
I urge you to convey to HCFA your opposition to the inclusion of professional
orthotics and prosthetics healthcare services in a competitive bidding
process.
Thank you for your consideration of this very important and timely issue, and
I will look forward to the opportunity of addressing this issue with you
further.
Sincerely,
John N. Billock, CPO,
Clinical/Executive Director
ADDITIONAL PETITIONS OF YOUR SUPPORT
The above information and the issues surrounding HCFA's decision to include
professional Orthotic healthcare services in a competitive bidding project
have been reviewed and discussed in detail with the entire staff at our
Centre. The following are the names and signatures of those individuals, who
are constituents in our State and who join me in this effort to seek your
assistance in this very important matter:
Kathi E. Ensweiler, C.O., C.Ped. ________________________________ Date:
Jean A. Pasini, C.P. ________________________________
Date:
Dottie J. Billock ________________________________
Date:
Kathleen A. Fike ________________________________
Date:
Additional Staff Names Signatures
Date:
This a repost attempt of my letter referenced in my previous post as it did
not post with the attached file. OANDP-L will no longer accept attached
files to the Listserver. You will therefor find my letter in body of this
post and if you would like it in its original WORD for Windows DOC file
format version just request it from me directly.
John N. Billock, CPO, Clinical Director
Orthotics & Prosthetics Rehabilitation Engineering Centre
700 Howland-Wilson Road, SE
Warren, Ohio 44484 USA
========================================================
March 6, 2000
The Honorable George Voinovich
U.S. Senate
317 Hart Senate Office Building
Washington, D.C. 20510
Re: Exclusion of Professional Orthotic or Prosthetic Healthcare Services in
HCFA Competitive Bidding Projects
Dear Senator Voinovich:
Enclosed you will find a copy of a letter I have sent to HCFA Administrator,
Nancy-Ann DeParle, regarding HCFA's plans to inappropriately include
professional Orthotic healthcare services in a competitive bidding
demonstration project.
On January 7, 2000, the Health Care Financing Administration (HCFA) published
a notice in the Federal Register requesting the Office of Management and
Budget (OMB) to conduct an emergency review by February 15, 2000, of the
eight bidding forms necessary to implement a second Medicare competitive
bidding demonstration project. Although a site for this demonstration
project has yet to be determined, HCFA announced in the notice that the
products to be offered for competitive bidding include oxygen equipment and
supplies, hospital beds, standardized orthotic products, manual wheelchairs,
and nebulizer drugs.
As a constituent who supported you in your election to the Senate, I am
writing to express my concerns on the above and to seek whatever support you
can offer to prevent this travesty from continuing further. Besides the
obvious quality of care issues conveyed in my letter to Ms. DeParle,
HCFA/Medicare reimbursement rates for professional orthotic and prosthetic
(O&P) healthcare services have been controlled by Medicare at an approximate
average of 1% per year over the past 15 years. Needless to say, O&P
healthcare costs have been well controlled, and in many cases are inadequate,
for the level of care required. Along with this fact, the HCFA/Medicare
reimbursement levels have become the national standard by which most, if not
all, private healthcare insurance carriers determine their usual and
customary O&P reimbursement levels. Again, based on this fact alone, one can
only conclude the cost of O&P is not excessive or inappropriate! Frankly,
there is an alarming number of professional O&P practitioners who are leaving
the profession as a result of the level that declining reimbursement rates
have reached.
During this same time, HCFA has all but ignored the obvious confusion of what
constitutes the provision of professional Orthotic and Prosthetic healthcare
services with the provision of durable medical equipment (DME) supplies. (To
clarify, the provision of professional O&P healthcare services involves both
clinical and technical services related to the evaluation, design and
development of custom fabricated and custom fit orthoses (orthopedic braces)
and prostheses (artificial limbs). The provision of DME supplies involves
the dispensing of manufactured devices and supplies such as crutches, canes,
hospital beds, wheelchairs, ostomy supplies, etc.) However, both providers
-- those of us who are qualified to provide professional O&P healthcare
services, as well as those providers who sell and/or rent DME supplies or
equipment -- have equal access to the same O&P L-codes, which are used for
billing purposes. This has obviously led to well-documented fraudulent
billings to Medicare by unscrupulous DME suppliers who are not qualified to
provide O&P healthcare services. This fraud and abuse by non-qualified
providers has been documented time after time, in report after report,
supporting and encouraging the need for provider qualifications to control
the ever-increasing fraudulent expenses to the Medicare system.
In 1997,the OIG issued a report entitled, Medicare Orthotics, which was
built on the findings of the 1994 Report referred to in my letter to Ms.
DeParle. This report clearly recommended the need for new provider standards
for professional O&P practitioners to limit access to the O&P L-codes to
qualified providers. This has not yet occurred, even after HCFA agreed with
this recommendation.
Because of HCFA's unwillingness to identify qualified O&P healthcare
providers and limit access to the O&P L-codes to these qualified providers,
the fraud and abuse by unqualified providers continues, as well as the
confusion between O&P services and DME supplies. Therefore, we, as qualified
providers of O&P services continue to inappropriately bear the brunt of
HCFA's efforts to control the non-legitimate use of the O&P billing codes by
the unqualified suppliers. Competitive bidding is now just one more example
of HCFA's misguided efforts to control this abuse
Also, HCFA's application of competitive bidding to general or standardized
orthotic products or devices is inappropriate because it undervalues the
critical service component of orthotic care. Despite repeated assurances
that HCFA would not use competitive bidding in the area of O & P, they now
clearly intend to do so!
Again, I am opposed to the inclusion of orthotics or prosthetics in any of
HCFA's competitive bidding demonstration projects for the primary reasons
stated in my letter to Ms. DeParle. In addition to my comments above and
those stated in the enclosed letter, competitive bidding eliminates the
beneficiary's choice of provider, which is imperative when the Medicare item
or service at issue is customized to the individual needs of a patient and
the clinical component of care is every bit as important as the O&P device
itself. More importantly, contracting with the lowest bidder will lead to a
race to the bottom and jeopardize the quality of the orthotic and/or
prosthetic devices and services. Competitive bidding would also adversely
affect O&P services, which require high levels of training, technology,
materials and a clinical environment. In addition to interrupting
long-standing relationships between patients and providers, competitive
bidding is particularly inappropriate for customized services and devices
such as O & P.
I urge you to convey to HCFA your opposition to the inclusion of professional
orthotics and prosthetics healthcare services in a competitive bidding
process.
Thank you for your consideration of this very important and timely issue, and
I will look forward to the opportunity of addressing this issue with you
further.
Sincerely,
John N. Billock, CPO,
Clinical/Executive Director
ADDITIONAL PETITIONS OF YOUR SUPPORT
The above information and the issues surrounding HCFA's decision to include
professional Orthotic healthcare services in a competitive bidding project
have been reviewed and discussed in detail with the entire staff at our
Centre. The following are the names and signatures of those individuals, who
are constituents in our State and who join me in this effort to seek your
assistance in this very important matter:
Kathi E. Ensweiler, C.O., C.Ped. ________________________________ Date:
Jean A. Pasini, C.P. ________________________________
Date:
Dottie J. Billock ________________________________
Date:
Kathleen A. Fike ________________________________
Date:
Additional Staff Names Signatures
Date:
Citation
“US-POLITICS: Exclusion of Orthotic Services in HCFA Competitive Bidding Project,” Digital Resource Foundation for Orthotics and Prosthetics, accessed November 2, 2024, https://library.drfop.org/items/show/213988.
