VIEW OUR VIDEO and written UPDATE on Medicare Reform, RAC Audits, and the Physician Documentation Template

VIEW OUR VIDEO and written UPDATE on Medicare Reform, RAC Audits, and the Physician Documentation Template

8/9/2013

VIEW OUR VIDEO and written UPDATE on Medicare Reform, RAC Audits, and the
Physician Documentation Template

A number of legislative and regulatory developments occurred in July that
impact orthotics and prosthetics. NAAOP offers this brief update for your
review. Please see the link below to view our video podcast. In addition to
viewing this on your computer you can now view the video on your iPad,
iPhone or Android.

Medicare reform, RAC Update, and Physician Template Developments
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. Medicare Physician Fee Schedule: The House Energy & Commerce Committee in
July passed legislation to fix the Medicare physician fee schedule
permanently, rather than another annual patch. There is some momentum this
year to attempt to finally address this annual problem in a comprehensive
way. Unfortunately, the cost of this bill is not currently offset by other
Medicare cuts. This means that ALL Medicare providers and suppliers are
subject to reductions in reimbursement and other policy proposals designed
to save Medicare money, assuming this bill proceeds through the legislative
process. O&P is not exempt from this list of targets, but the profession
also has a proactive proposal for Congress' consideration, the Medicare O&P
Improvement Act. Passage of a Medicare bill this year creates risks, but it
also creates opportunities to press for passage of this important bill,
which would link the qualifications of O&P providers with the ability to
bill the Medicare program.

. RAC Audit Update: Certain Recovery Auditors (RACs) began rescinding a
number of O&P audits in July with dates of service before August 2011. This
was very encouraging in that CMS has long maintained that the OIG report
issued in August 2011 entitled, Questionable Billings for Lower Limb
Prosthetics, did not prompt CMS to change policy, but only to clarify it.
Merely clarifying policy does not require CMS to issue changes with public
notice and comment, as they must do with major policy changes. This issue is
at the heart of the lawsuit against CMS filed by AOPA. In response, a number
in the O&P field believed victory on the RAC issue was at hand. But CMS
seems to have reacted by disavowing knowledge of any coordinated decision on
this issue. This leaves a number of questions that are not yet resolved.
NAAOP will report new developments on the RAC issue as they occur.

. Physician Documentation Template: CMS recently held its second Open Door
Forum on its interest in developing a documentation template for lower limb
prostheses that will be used in connection with physician electronic medical
records. The data elements are almost exclusively medical in nature and are
clearly directed at physicians, not prosthetists. The template does not
address the functional status and potential functional needs of the
beneficiary. These and other concerns were presented to CMS through written
comments sent by the O&P Alliance in June, but CMS has not yet responded to
these concerns. NAAOP will press the case directly with CMS and in
conjunction with the O&P Alliance.

Paul E. Prusakowski, CPO, FAAOP
President

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