OTS/OTC, OR2 or OR3 -- Two Places at Once, How Can It Be?
Levy, Mark B
Description
Collection
Title:
OTS/OTC, OR2 or OR3 -- Two Places at Once, How Can It Be?
Creator:
Levy, Mark B
Date:
5/7/2013
Text:
In early 2012, CMS posted -- for comment only? Not clear -- a list that initially identifies the 2012 Healthcare Common Procedure Coding System (HCPCS) codes that are considered OTS orthotics.
<URL Redacted>
I believe there was a good bit of commenting, but have seen nothing resembling a determination, final guidance, or revised list addressing the comments received. FYI, but not necessarily germane to this question, the Ohio licensing Board comment is here:
<URL Redacted>
Thus, that list of OTS/OTC devices is proposed to be or perhaps should have been migrated fully to the OR3 NSC category of orthotic devices.
However, the CMS Guidance document providing reference information for DMEPOS Suppliers completing an enrollment application, Transmittal 865, Change Request 7333, Date: March 4, 2011, Attachment C, classifies most or many of the 2012 iteration of OTS/OTC devices under the heading “OR02 - Orthoses: Pre-fabricated (non custom fabricated). To the best of my knowledge, that is the reference set being utilized for screening enrollment applications.
<URL Redacted>
Are any correspondents on this list aware of anything from the federal level that addresses this discrepancy? I recognize the likelihood that the list will become the inventory basis for competitive bid when it hits this sector. In the interim … how can those devices be listed simultaneously by CMS enforcement authorities in categories which are intended to be mutually exclusive?
Federal folk watching this list are free and encouraged to respond.
Mark B. Levy, Board Director
State Board of Orthotics, Prosthetics and Pedorthics
77 S. High St., 18th Floor
Columbus, OH 43215
tel: 614-466-1157
fax: 614-387-7347
email: <Email Address Redacted> <mailto:<Email Address Redacted>>
website: http://opp.ohio.gov <blocked:: http://opp.ohio.gov >
<URL Redacted>
I believe there was a good bit of commenting, but have seen nothing resembling a determination, final guidance, or revised list addressing the comments received. FYI, but not necessarily germane to this question, the Ohio licensing Board comment is here:
<URL Redacted>
Thus, that list of OTS/OTC devices is proposed to be or perhaps should have been migrated fully to the OR3 NSC category of orthotic devices.
However, the CMS Guidance document providing reference information for DMEPOS Suppliers completing an enrollment application, Transmittal 865, Change Request 7333, Date: March 4, 2011, Attachment C, classifies most or many of the 2012 iteration of OTS/OTC devices under the heading “OR02 - Orthoses: Pre-fabricated (non custom fabricated). To the best of my knowledge, that is the reference set being utilized for screening enrollment applications.
<URL Redacted>
Are any correspondents on this list aware of anything from the federal level that addresses this discrepancy? I recognize the likelihood that the list will become the inventory basis for competitive bid when it hits this sector. In the interim … how can those devices be listed simultaneously by CMS enforcement authorities in categories which are intended to be mutually exclusive?
Federal folk watching this list are free and encouraged to respond.
Mark B. Levy, Board Director
State Board of Orthotics, Prosthetics and Pedorthics
77 S. High St., 18th Floor
Columbus, OH 43215
tel: 614-466-1157
fax: 614-387-7347
email: <Email Address Redacted> <mailto:<Email Address Redacted>>
website: http://opp.ohio.gov <blocked:: http://opp.ohio.gov >
Citation
Levy, Mark B, “OTS/OTC, OR2 or OR3 -- Two Places at Once, How Can It Be?,” Digital Resource Foundation for Orthotics and Prosthetics, accessed December 24, 2024, https://library.drfop.org/items/show/235161.
