Re: CMS/ Medicare Survey/0PINION

Re: CMS/ Medicare Survey/0PINION

Tony Barr

2/6/2007

IN MY HUMBLE OPINION AND VETERAN PARTICIPANT OF THE FAILED CMS NEGOTIATED
RULES COMMITTEE HEARINGS, MY REPLIES ARE STATED IN CAPS BELOW.

TONY BARR

Dear List

It took about 20 minutes, but I just participated in a survey about Medicare
contractors, representatives, the appeals process, audits, etc.
I expressed several times that I felt the representatives had little
knowledge about prosthetics and orthotics when it comes to the appeals and
audit processes.CF CPO

AS A PARTICIPANT IN THE NEG REG COMMITTEE HEARINGS, MEDICARE/MEDICAID AND
CMS DO HAVE A LITTLE KNOWLEDGE IN COMPREHENSIVE O&P BUT SO DO MANY
PROSTHETISTS AND ORTHOTISTS WHOM ARE LEGALLY PERMITTED TO PRACTICE 'YOUR
PROFESSION'IN THE USA, WITH OR WITH OUT CREDENTIALS OR A STATE LICENSE IN 39
STATES, INCLUDING MICHIGAN.TB

WHAT COMPLICATES IDEOLOGIES EVEN MORE ,ARE THAT CERTIFIED ORTHOTISTS ARE
ABLE AND PERMITTED BY BOTH CREDENTIALING ASSOCIATIONS, TO PROVIDE AND BILL
FOR PROSTHETIC SERVICES AND VISA VERSA AS LONG AS CERTIFEES DON'T
REPRESENT THEMSELVES AS 'CERTIFIED' IN THAT PARTICULAR DISCIPLINE TO THE
PATIENT RECEIVING THE SERVICES!!TB

THE RESULT IS CROSS CREDENTIALLING IS CONDONED AND NO OVERSIGHT OR
ACCOUNTABILITY IS PROVIDED BY EITHER CREDENTIALING ASSOCIATIONS.TB

ONLY OBTAINING A STATE LICENSE IN EITHER O OR P WOULD NOT LEGALLY PERMIT
CROSSING OVER INTO ANOTHER DISCIPLINE THAT YOU ARE NOT PROPERLY AND DULY
LICENSED IN.TB

I also expressed that our field is very incorrectly categorized under DME.
We are not leg and brace stores, but practitioners who provide very unique
and custom services. Sometimes those services are very difficult to
describe and the representatives in turn deny our claims.CF CPO

O&P SERVICES ARE CLASSIFIED AS DME SINCE YOUR NATIONAL TRADE ASSOCIATIONS
HAVE MEMBERS OF BOTH.TB

My responses here were based on my own attendance at some local meetings.
99% of the meeting dealt with wheelchair rentals, and oxygen supplies. The
educators were very well versed in equipment
rental, but had extreme difficulty answering any O and P questions.
(they even wondered why we were in attendance) Again, DME is very different
from O and P.CF CPO

I AGREE BUT NOTHING WILL CHANGE UNTIL YOUR 'PROFESSION' IS LICENSED BY THE
STATE IN WHICH YOU PRACTICE AND COMPREHENSIVE O&P IS SEPARATED FROM DME
WITHIN THE NATIONAL TRADE O & P ASSOCIATIONS.TB


THERE ARE WHEEL CHAIR AND OXYGEN EQUIPMENT MANUFACTURES WITHIN THE
MEMBERSHIP RANKS OF AOPA.TB

COINCIDENTLY THE RAMPANT FRAUD AND ABUSE HAS BEEN IN THIS AREA OF DME, NOT
O&P.
HOWEVER YOU ARE AND WILL CONTINUE TO BE, ALL LUMPED TOGETHER AS DME
PROVIDERS.

Here are three more survey questions for O& P providers AND FOR CMS:

1) DO YOU THINK A 'CERTIFIED PROSTHETIST' IS PROPERLY TRAINED AND HAS
RECEIVED ADEQUATE EDUCATION TO PROPERLY EVALUATE, FABRICATE AND FIT A
SCOLIOSIS ORTHOSIS TO A PATIENT?

2) DO YOU THINK A 'CERTIFIED ORTHOTIST' IS PROPERLY TRAINED AND HAS RECEIVED
ADEQUATE EDUCATION TO PROPERLY AND SAFELY AND SAFELY EVALUATE, FABRICATE
AND FIT A A/K ,B/K OR U/E PROSTHESIS TO A PATIENT?

3) WHAT IS THE POINT OF CERTIFICATION WHEN IT IS ONLY OPTIONAL AT BEST IN 39
STATES, TO DELIVER AND BILL FOR COMPREHENSIVE O&P TREATMENT AND PROVIDERS
WHOM CROSS CREDENTIAL INTO ANOTHER ALLIED HEALTH CARE SCIENCE THAT THEYU ARE
NOT TRAINED IN, IS PERMITTED BY THE CREDENTIALING ASSOCIATION AND CMS AND
OTHER THIRD PARY PAYERS ?

Anthony T. Barr
President
Barr Foundation
www.oandp.com/barr
www.ErtlReconstruction.com