New Medicare AFO Regulations
Wil
Description
Collection
Title:
New Medicare AFO Regulations
Creator:
Wil
Date:
12/23/2012
Text:
Hello Colleagues and Guests,
Here we are, once again. I believe the DMEPDAC listing for AFOs will no
longer be correct starting in 2013 when the new LCD requirements for
AFOs and KAFOs are implemented. Does anyone else agree with this
assessment?
If I am correct, CMS is in direct conflict with their own regulations.
How, for example, can they publish DMEPDAC approved AFO products from
various manufacturers that are assigned to specific AFO LCodes when a
good part of the products, if not all, will no longer meet the
definition of an AFO, as listed in this most recent AFO-KAFO LCD
publication? Or, am I reading something into these regulations that I
should not? I read that the proximal termination point for an
ankle-foot-orthosis SHALL be located between the top of the
gastrocnemius and the apex of the fibula head, which is generally 2-4cm
below the apex of the fibula head.
In my opinion, this is just another attempt by CMS to reign in fraud and
abuse because they have likely come across a boat load of FOs that are
being billed as AFOs. Otherwise, why would such a regulation be
implemented? Frankly, it won't stand. In the professional orthotic world
it can't, unless the entire dictionary and nomenclature for orthotics is
rewritten. There are other more effective ways to reign in fraud and
abuse and I hope that one day someone in government will hear our plea
for meaningful change.
Standing in manure up to your ankles is not a big deal, unless you are
standing on your head. So lets all pull together and stay upright for as
long as we can.
Merry Christmas and Happy Holidays.
Wil Haines, CPO
MaxCare Bionics
Avon, IN 46123
Here we are, once again. I believe the DMEPDAC listing for AFOs will no
longer be correct starting in 2013 when the new LCD requirements for
AFOs and KAFOs are implemented. Does anyone else agree with this
assessment?
If I am correct, CMS is in direct conflict with their own regulations.
How, for example, can they publish DMEPDAC approved AFO products from
various manufacturers that are assigned to specific AFO LCodes when a
good part of the products, if not all, will no longer meet the
definition of an AFO, as listed in this most recent AFO-KAFO LCD
publication? Or, am I reading something into these regulations that I
should not? I read that the proximal termination point for an
ankle-foot-orthosis SHALL be located between the top of the
gastrocnemius and the apex of the fibula head, which is generally 2-4cm
below the apex of the fibula head.
In my opinion, this is just another attempt by CMS to reign in fraud and
abuse because they have likely come across a boat load of FOs that are
being billed as AFOs. Otherwise, why would such a regulation be
implemented? Frankly, it won't stand. In the professional orthotic world
it can't, unless the entire dictionary and nomenclature for orthotics is
rewritten. There are other more effective ways to reign in fraud and
abuse and I hope that one day someone in government will hear our plea
for meaningful change.
Standing in manure up to your ankles is not a big deal, unless you are
standing on your head. So lets all pull together and stay upright for as
long as we can.
Merry Christmas and Happy Holidays.
Wil Haines, CPO
MaxCare Bionics
Avon, IN 46123
Citation
Wil, “New Medicare AFO Regulations,” Digital Resource Foundation for Orthotics and Prosthetics, accessed November 5, 2024, https://library.drfop.org/items/show/234395.
