PL106-554

Gary A. Lamb

Description

Title:

PL106-554

Creator:

Gary A. Lamb

Date:

1/25/2001

Text:

List members;
In recent weeks, there has been a lot of List Serve mail regarding concerns
about the recent federal legislation passed as part of the Medicare
Giveback bill. Some have expressed concern that the American
Academy of Orthotists and Prosthetists has remained silent on this
issue. I am a member of the Academy's Board and Chair of the Professional
Issues Council. I am reminded that one job I seem to be failing in is,
keeping you apprised of what we are doing. The Academy is posting
information regularly as it occurs on its web site. This is proving not to
be the most effective
method of communication. We will attempt to provide a more effective
communication plan. Member suggestions will be appreciated.

One of the most challenging issues as a member of the board of directors is
expressing a personal opinion. Many people see a personal opinion as a board
position or opinion. (Reminds me of the U.S. senate's confirmation hearing
process, i.e. individuals in a leadership role are obligated to do the work
of the people even when it may conflict personal opinion.) For the board to
act responsibly, the conveyance of an opinion is, unfortunately, a slow and
laborious task. It requires the opportunity to discuss the matter in depth
and reach a consensus, or for the board to delegate the responsibility. The
board then has to approve the written opinion by a majority. The membership
of the Academy is a diverse
group, and the board must determine what is best for the Academy in hopes
the majority of the members will concur with the actions it takes. Hearing
members and others beating us in the public square, rather than approaching
us in a private request or inquiry of our actions, further reinforces the
reticence of individuals on the board to speak in public.

Following you will find a letter from (then) President Bash, to Rep. Thomas,
a sponsor of the senate bill 1451, now known as policy law (PL) number
106-554. We were writing in support of specific draft language that inserted
the
CAAHEP qualifications. Following the letter you will find our position
papers, specific ones referenced in the letter were attached.
(also found here: www.oandp.org) The last page attached is the policy on
advocacy, if you are a member of the Academy, I hope you will commit the
process to memory. Specifically, Members are encouraged to bring issues of
concern to the PIC, Licensure and Credentialing Committee, and the State and
Federal Legislative Policy Committee. Those groups will determine the
significance and impact of the
issue and develop a plan of appropriate action and make recommendations to
the Board. You as members need to let us know your concerns! If we, as
a board or committee, move on an issue that we feel is important
and no members seem to care, we hear, why did you WASTE all the time,
energy and
money on that? We have relationships with AOPA and NAAOP to stay
informed on the issues, but we need to hear from you, OUR MEMBERS of your
concerns.

I thank you for the privilege of serving you, and ask that you remain,
active, vigilant, and utilize the existing structure in the Academy to
address your issues of concern.


With consensus,
Respectfully,
Gary A. Lamb CO, FAAOP





October 2, 2000


Representative William M. Thomas
2208 Rayburn Building
Washington, DC 20515




Dear Congressman Thomas,


I am writing on behalf of the over two thousand members of the American
Academy of Orthotist and Prosthetist (the Academy). We wish to express our
support of S.1451 and applaud your efforts to see meaningful legislation
enacted that would prevent the ongoing fraud and abuse by unqualified
providers or orthotic and prosthetic healthcare services, as identified in
numerous reports by the Office of Inspector General.


The Academy, as an organization, represents the professional and educational
needs of orthotic and prosthetic practitioners, who are credentialed by the
American Board for Certification in Orthotics and Prosthetics, with a
primary goal of assuring quality care through acceptable minimum standards
of practitioner education. For this reason, we strongly support the new
language of S.1451, which now recognizes the Commission on Accreditation of
Allied Health Education Programs (CAAHEP) education standards for Orthotists
and Prosthetists. The American Medical Association (AMA) also recognized
the CAAHEP educational program standards for orthotists and prosthetists set
forth back in 1992.


This much needed legislation will serve the public in many ways. The
reduction of fraud and abuse by establishing practitioner qualifications,
will save the American taxpayers an estimated 8 million to 20 million
dollars per year. Additionally, it will provide the unknowing public with
minimum standards that must be met prior being fitted with a orthotic or
prosthetic device that could enable them to return to an active lifestyle or
potentially cause a decrease in function or recovery if improperly provided.


The Academy has been on record for several years regarding its support of
the CAAHEP education standards as they relate to the provision of custom
fabricated and fitted orthoses and prostheses, as evidenced by our attached
position statement.


Additionally, you will find copies of our position statement on the Minimum
Education Essentials & Credentialing for Providers of Comprehensive Orthotic
and Prosthetic Services, as well as our Pathway to Competency document,
which further clarify our position.


Again, we applaud your efforts to curb fraud and abuse, as well as protect
the public we serve.


With our sincerest regards and concern,




Stephanie Langdon- Bash CPO,FAAOP
President






Position Statements:
On Practitioners Giving Testimony
On Ethical Conduct of Orthotic and Prosthetic Practitioners
On the Provision of Custom-Fabricated, -Fitted and/or -Designed Orthoses and
Prostheses
On the Minimum Education Essentials & Credentialing for Providers of
Comprehensive Orthotic and Prosthetic Services
Position Statement on State Licensure
1. On Practitioners Giving Testimony
So that no confusion may exist as to whether an individual testifying is
representing the Academy, all Officers, Directors and Committee persons who
may be called upon to give testimony as an expert witness shall preface
any statement they may give with the following:
I am testifying as a certified practitioner and expert in the field of
orthotics and prosthetics, but not in any capacity as an Officer, Director
or Agent of any organization.
2. On Ethical Conduct of Orthotic and Prosthetic
Practitioners
In keeping with our mission, and in consideration of the Academy being the
professional organization representing practitioners credentialed by the
American Board for Certification in Orthotics and Prosthetics Inc. (ABC), it
is a primary objective of the Academy to advocate the highest standards of
professional and ethical conduct among all ABC-credentialed practitioners.
The Academy fully supports the enforcement of the ABC Canons of Ethical
Conduct and encourages the truthful reporting of unethical conduct to the
ABC Character and Fitness Committee for the appropriate action.
Any member of the Academy who has had his/her practitioner certification
revoked or suspended by the ABC will automatically lose his/her membership.

3. On the Provision of Custom-Fabricated, -Fitted and/or-
Designed Orthoses and Prostheses
The Academy is the national professional organization credentialed by the
ABC. Specifically, these are practitioners providing disabled and/or injured
persons a unique medical rehabilitation service that involves a clinical
assessment and evaluation leading to the custom designing, development,
and/or fitting of an orthosis or prosthesis. An 'orthosis' by definition is
an external supportive and/or assistive device interfaced externally to the
human body for the treatment of neuromuscular and/musculoskeletal deficit
secondary to disease, trauma or congenital disorders. A 'prothesis' by
definition is an external supportive and/or assistive device
interfaced externally to the human body for the replacement of an absence
secondary to disease, trauma or congenital disorders.
Given the unique blend of medical and engineering sciences, as well as
technical skills which one must possess to ensure competency in the delivery
of comprehensive O&P services, the Academy supports the maintenance of
minimum education and credentialing requirements of the ABC. The Academy
further supports the ABC's ethical standard that requires O&P services be
prescribed by a physician or an appropriately licensed health care provider.
In that regard, it is further the position of the Academy that Custom
Fabricated, Fitted and/or Designed Orthoses and Prostheses clearly relate
to the delivery of comprehensive orthotic and prosthetic services and that
their provision should appropriately match the minimum ABC standards.
The ABC credentials have been the most widely accepted minimum standards
of care for providers of comprehensive O&P services since they were
developed in 1948, with the strong encouragement and close assistance of the
American Academy of Orthopedic Surgeons (AAOS). Since that time, the ABC
credentials and standards have become the most widely recognized for
ensuring the minimum competency of appropriately trained and qualified O&P
allied health care providers in the delivery of comprehensive O&P services.
Further, the standards in place for the credentialing of ABC practitioners
are the only standards that meet the minimum education essentials and
standards recognized by the Commission on Accreditation of Allied Health
Education Programs (CAAHEP) and the American Medical Association (AMA).
These distinctions and recognitions were achieved in recent years when the
minimum education essentials for accredited educational programs for
orthotists and prosthetists were formally recognized by the CAAHEP and AMA
in 1993. CAAHEP, formerly known as the AMA's Committee on Allied Health
Education and Accreditation (CAHEA), is the most widely recognized
independent non-profit allied health education accreditation organization in
the United States.
These minimum O&P education essentials were developed by the National
Commission on Orthotic and Prosthetic Education (NCOPE) with the support and
cooperation of the AMA, the Academy and the American Orthotic and Prosthetic
Association (AOPA). This collaborative effort eventually led to the adoption
of Scope's Essentials and Guidelines for an Accredited Educational Program
for the Orthotist and Prosthetist in 1993 and their formal recognition by
CAAHEP. The NCOPE Essentials and Guidelines serve as the foundation for
education and experience requirements established by the ABC for
individuals wishing to pursue a career pathway in orthotics and prosthetics,
as an ABC Certified Prosthetist and/or Orthotist.
Additionally, the ABC practitioner credentials and educational standards
were also recognized within the Omnibus Reconciliation Act of 1980, which
led to the establishment of Federal Laws, defined within the U. S. Code of
Federal Regulations for Public Health, Health Care Finance Administration
and Department of Human Services, governing the regulation of Orthotic and
Prosthetic services provided within a Comprehensive Out-Patient
Rehabilitation Facility (CORF). The Federal Regulations regarding this Act
were enacted in October of 1983 and specifically require that O&P services
be provided by an ABC Certified Orthotist and Prosthetist in all recognized
Comprehensive Out-Patient Rehabilitation Facilities and further documents
recognition of the comprehensiveness of the ABC credential and education
standards. Specifically, the CORF Federal Regulations under Subpart D of
those Regulations, which define Comprehensive Out-patient Rehabilitation
Facility Services, and Subpart B, which define the Conditions for
Participation, under Section 485.70, Personnel Qualifications, recognize
both the education track and practitioner credentialing standards of the
ABC.
Over the past 47 years, the development of the ABC's credentialing
standards, as in other professions, has progressed from the requirement of a
high school diploma and on-the-job apprenticeship training, to an associate
of arts degree in 1977 and then to a bachelor of science degree in 1986.
These advanced education requirements were brought on by a comprehensive
multi-professional effort involving allied health educators and
administrators, physicians, O&P practitioners, students and government
officials who set out to assess and address the growing need for higher
education as the O&P practitioners' allied health responsibilities and
technology progressed. These efforts are well documented in the Ponte Vedra
I Workshop, held in June of 1970 and the Ponte Vedra II Workshop held in
February of 1976. Additionally, these efforts clearly identified a sincere
effort on the part of the profession to address all aspects of the
profession with respect to its current and future practitioner education
needs.
In all respects, orthotic and prosthetic services are very unique and
complex allied health medical services which require a well structured
education combined with a knowledge and skills in a variety of medical and
engineering sciences for one to provide comprehensive services at a
minimum level of acceptable competency. The American Academy of Orthotists
and Prosthetists believes that the minimum level of competency assurance
for one to appropriately and knowledgeably design, develop, and fit custom
fabricated orthoses and/or prostheses should continue to be the already
accepted minimum education essentials established by the NCOPE and
embodied within the ABC's practitioner credentialing process.
Therefore, in the best interest of injured and/or disabled persons, it is
the position of the Academy that the credentialing requirements of the ABC
practitioner certification as a Certified Orthotist (CO), Certified
Prosthetist (CP), and/or Certified Prosthetist/Orthotist (CPO) should be the
minimum credentialing standard for the allied health care providers of
comprehensive O&P services. This is particularly important in the absence
of state licensure of orthotists and prosthetists in all but one state in
the US. With an objective review of the various orthotic and/or prosthetic
credentialing programs now in existence, the ABC credential is the most
appropriately qualified credential for ensuring minimum competency in the
delivery of comprehensive orthotic and prosthetic services involving custom
designed, fabricated, and/or fitted orthotic and prosthetic devices.

4. On the Minimum Education Essentials & Credentialing for
Providers of Comprehensive Orthotic and Prosthetic
Services
It is the position of the AAOP that the delivery of comprehensive orthotic
and prosthetic services should appropriately match the minimum education
and experience requirements required by the ABC for orthotic and prosthetic
practitioners. These currently accepted ABC standards are embodied within
the Essentials and Guidelines for an Accredited Educational Program for the
Orthotist and Prosthetist developed by the National Commission on Orthotic
and Prosthetic Education (NCOPE). These Essentials and Guidelines were
developed with the support and cooperation of the AAOP, the American
Orthotic and Prosthetic Association (AOPA) and the American Medical
Association (AMA). They serve as the foundation for the minimum education
and experience established by the ABC for individuals wishing to pursue a
career pathway in orthotics and prosthetics, as an ABC Certified Prosthetist
and/or Orthotist.
The development of the NCOPE's Essentials and Guidelines for an Accredited
Educational Program for the Orthotist and Prosthetist led to formal
recognition of Orthotics and Prosthetics as an allied health occupation by
the AMA's Council on Medical Education in 1992. This in turn led to a
collaborative relationship with the AMA's Commission on Allied Health
Education and Accreditation (CAHEA) in the accreditation of educational
programs in the profession of orthotics and prosthetics which eventually led
to formal recognition of NCOPE's Essentials and Guidelines by the AMA's
Council on Medical Education in 1993. CAHEA, which is now known as the
Commission on Accreditation of Allied Health Education Programs (CAAHEP), is
the most widely recognized independent non-profit allied health education
accreditation organization in the United States.
In that regard, ABC credentialed orthotic and prosthetic practitioners
provide to disabled and/or injured persons a unique medical rehabilitation
service that involves a clinical evaluation and assessment that leads to the
custom designing, fitting and/or development of an orthosis or prosthesis.
An orthosis by definition is an external supportive and/or assistive
device interfaced externally to the human body for the treatment of
neuromuscular and/or musculoskeletal deficit secondary to disease, trauma or
a congenital disorder involving the arms, legs and/or spine. A prosthesis
by definition is an external supportive and/or assistive device interfaced
externally to the human body for the replacement of a limb absence secondary
to disease, trauma or a congenital disorder involving the arms and/or legs.
Given the unique blend of medical and engineering sciences, as well as
technical skills that one must possess to ensure competency in the delivery
of comprehensive O&P services, the Academy supports the maintenance of
minimum education and credentialing requirements of the American Board for
Certification in Orthotics and Prosthetics. The Academy further supports the
ABC's ethical standard that requires O&P services be prescribed by a
physician or an appropriately licensed health care provider.

5. Position Statement on State Licensure
As the pre-eminent professional organization in orthotics and prosthetics,
it is the mission of the American Academy of Orthotists and Prosthetists
(AAOP) to promote high standards of patient care through education, patient
advocacy, literature and research. In keeping with this mission, and as the
ONLY professional organization representing practitioners credentialed by
the American Board for Certification in Orthotics and Prosthetics Inc.
(ABC), the Academy is supportive of the highest standards for providers to
ensure quality comprehensive orthotic and prosthetic services for patients.
The Academy believes:
Licensure requirements benefit the patient requiring orthotic or prosthetic
services by demanding established criteria for minimum education essentials
and experiential requirements. The standards we endorse are embodied within
the Standards and Guidelines for an Accredited Educational Program for the
Orthotist and Prosthetist developed by the National Commission on Orthotic
and Prosthetic Education (NCOPE), and are required for certification by the
American Board for Certification in Orthotics and Prosthetics (ABC). These
standards were also recognized by the American Medical Association's Council
on Medical Education in 1993, and by the Commission on Accreditation of
Allied Health Education Programs (CAAHEP).

Licensure requirements are in the best interests of the profession in that
they give official status to the practice of the profession, establish a
recognized scope of practice for Orthotists and Prosthetists, and will be
recognized by other healthcare practitioners in the crossover of patient
care responsibilities.
Therefore, the Academy endorses state licensure of Orthotists and
Prosthetists as the preferred method of establishing patient protection
mechanisms through legislated state standards, provided those standards are
equivalent to those developed by the National Commission on Orthotic and
Prosthetic Education and recognized by the Commission on Accreditation of
Allied Health Education Programs.







Board Adopts Advocacy Policy
By approving a short, simply-worded statement saying it
will monitor the formulation of public policy that has an impact on the
provision and quality of orthotic and prosthetic care, the Board took a
significant step forward in creating an advocacy role for the Academy.
Professional Issues Council (PIC) Chair Gary A. Lamb, CO, FAAOP applauded
the move as one of the best things the Board has done on behalf of the
members. The parameters of issues in which the Academy will involve itself
are described, in part, in its position statements on The Provision of
Custom-Designed, -Fabricated and/or -Fitted Orthoses and Prostheses, The
Ethical Conduct of Orthotic and Prosthetic Practitioners and The Minimum
Education Essential & Credentialing for Providers of Comprehensive Orthotic
and Prosthetic Services. The PIC will act as the clearinghouse for
inquiries about issues affecting the profession.
Members are encouraged to bring issues of concern to the PIC, Licensure and
Credentialing Committee, and the State and Federal Legislative Policy
Committee. Those groups will determine the significance and impact of the
issue and develop a plan of appropriate action and make recommendations to
the Board. Once a position has been established and the plan of action
adopted by the Board, formal notification of the Academy's position will be
communicated to members and other O&P organizations through the website and
other communication channels.

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Citation

Gary A. Lamb, “PL106-554,” Digital Resource Foundation for Orthotics and Prosthetics, accessed November 2, 2024, https://library.drfop.org/items/show/215751.