FW: Form letters
Jeff Arnette
Description
Collection
Title:
FW: Form letters
Creator:
Jeff Arnette
Date:
8/31/2015
Text:
Colleagues,
I have had a lot of feedback and response to the proposal I put out last week, enough that I have made two form letters. If you are on board with the points in my proposal please feel free to use these.
Quick recap, here is the plan of action we are pushing for:
-Rescind,
-Separate O&P from DME
-Form an O & P Advisory board within CMS to solve this and previous friction, and preempt further trouble.
We came to this conclusion partly from working with Region C to set up an advisory board due to the audit situation.
We have some momentum, let’s use it to get our foot in the door to future conversations.
FORM LETTERS BELOW MY SIGNATURE:
1. Short letter
<URL Redacted>
2. Long version
<URL Redacted>
Sincerely,
Brandon Arnette
Progressive Orthotic & Prosthetic Services
<Email Address Redacted> <mailto:<Email Address Redacted>>
www.progressivepo.com< <URL Redacted>>
9511 E. 46th St.
Tulsa OK, 74145
(918) 663 7077
YOUR LETTERHEAD
CMS directors, Stacey Brennan, MD, et al.
RE: Proposed LCD DL33787
Dear CMS Directors,
In regards to recent proposed changes in the CMS coverage of orthotics and prosthetics, Orthotists and Prosthetists have come together to unite with one voice for maintained coverage to CMS beneficiaries and reduction in overall cost of prosthetic care. We understand CMS Goals in cost containment, consolidation, and uniformity of care and want ultimately to reach these same goals in a way that is beneficial to the patient and fosters the development of new technologies to improve the health and lifestyle of every disabled American.
We humbly submit the following scenario as a solution:
1. We suggest that the draft LCD be rescinded, and code changes be delayed in order to allow Industry leaders, Amputee Advocates, and Prosthetic professionals to participate in a workable solution to reduce cost without negative impact to patient care.
2. We suggest that CMS permanently and finally separate Orthotic and Prosthetic devices and their respective L-codes from DME MAC. O&P care (with a very few exceptions) requires a highly trained professional to select and provide the necessary care to the patient. Orthotists and Prosthetists should be recognized as the LCMP that they are. Competitive bidding DME items should be placed under a separate coding structure, as these items require limited training or experience.
3. We suggest that an advisory board of prosthetic clinicians, amputees, and industry representatives be established to provide advice to CMS on consolidating coding, and coverage determination. Region C has already has such a board, the POE O & P advisory group, the membership is approved and consists of an optimal cross-section of clinicians, industry VIP's, and amputee advocates.
We further recommend CMS approve the Advisory Board to be a permanent voice to CMS practices and that the board have the following responsibilities to present a solution for Medicare coding structure now and in the future:
-Provide a proposal within a reasonable time frame for CMS to approve. We suggest 6-12 months
-Establish set quantifiable measures for defining K level
-Advocate for the patient
-Consolidate Prosthetic coding structures
-Establish updated base coding for each K level to include reimbursement of socket and component add on codes
Signed,
YOURNAMEHERE
YOUR LETTERHEAD
CMS directors
Attn: Stacey Brennan, MD
RE: Proposed LCD DL33787
Dear CMS Directors,
In regards to recent proposed changes in the CMS coverage of orthotics and prosthetics, Orthotists and Prosthetists have come together to unite with one voice for maintained coverage to CMS beneficiaries and reduction in overall cost of prosthetic care. We understand CMS Goals in cost containment, consolidation, and uniformity of care and want ultimately to reach these same goals in a way that is beneficial to the patient and fosters the development of new technologies to improve the health and lifestyle of every disabled American.
We have outlined three problematic areas of concern with the current LCD and the process that authored the proposed changes:
1. Proposed changes did not involve a panel of Certified or Licensed Orthotists/Prosthetists: CMS proposed changes and RAC audits have been carried out without peer review or proper understanding of the history of the services which are represented by the current coding system. We feel the lack of peer review in these changes is not in accordance with CMS policies and guidelines.
2. Repeatable Outcome Measures are not present to define K level or medical necessity: CMS has offered no repeatable measure for LCMP's to use to document a patient's K level. It has essentially been left up to subjective observation. In order to deem that services are or are not medically necessary CMS must offer a measurement of physical ability that is scientific and repeatable by the patient's therapist, physician, or prosthetist/orthotist.
3. Misunderstanding of Outdated Coding: We understand that CMS must cut unnecessary costs and that the current coding structure needs review. However, the current proposed LCD is insufficient in the provision of care that would be provided for patients. AOPA has laid out these concerns in the Executive Summary and summarized the negative impact to beneficiaries in detail:
4. http://www.aopanet.org/wp-content/uploads/2015/07/Proposed-Lower-Limb-Prosthesis-LCD-Summary-and-AOPA-Executive-Summary-for-Distribution-to-AOPA-Members.pdf
Proposal:
We humbly submit the following scenario as a solution:
1. We suggest that the draft LCD be rescinded, and code changes be delayed in order to allow Industry leaders, Amputee Advocates, and Prosthetic professionals to participate in a workable solution to reduce cost without negative impact to patient care.
2. We suggest that an advisory board of prosthetic clinicians and industry representatives be established to provide advice to CMS on consolidating coding, and coverage determination. Region C has already established a board of qualified, approved industry leaders, clinicians, and amputee advocates.
3. We suggest that CMS permanently and finally separate Orthotic and Prosthetic devices and their respective L-codes from DME MAC. O&P care (with a very few exceptions) requires a highly trained professional to select and provide the necessary care to the patient. Orthotists and Prosthetists should be recognized as the LCMP that they are. Competitive bidding DME items should be placed under a separate coding structure, as these items require limited training or experience.
We recommend that a CMS Advisory board be formed from the membership of the already established POE group for DME MAC Region C, as the membership is approved and consists of an optimal cross-section of clinicians, industry VIP's, and amputee advocates.
We recommend CMS approve the Advisory Board to be a permanent voice to CMS practices and that the board have the following responsibilities to present a solution for Medicare coding structure now and in the future:
-Provide a proposal within a reasonable time frame for CMS to approve. We suggest 6-12 months
-Establish set quantifiable measures for defining K level
-Advocate for the patient
-Consolidate Prosthetic coding structures
-Establish updated base coding for each K level to include reimbursement of socket and component add on codes
Signed,
YOURNAMEHERE
I have had a lot of feedback and response to the proposal I put out last week, enough that I have made two form letters. If you are on board with the points in my proposal please feel free to use these.
Quick recap, here is the plan of action we are pushing for:
-Rescind,
-Separate O&P from DME
-Form an O & P Advisory board within CMS to solve this and previous friction, and preempt further trouble.
We came to this conclusion partly from working with Region C to set up an advisory board due to the audit situation.
We have some momentum, let’s use it to get our foot in the door to future conversations.
FORM LETTERS BELOW MY SIGNATURE:
1. Short letter
<URL Redacted>
2. Long version
<URL Redacted>
Sincerely,
Brandon Arnette
Progressive Orthotic & Prosthetic Services
<Email Address Redacted> <mailto:<Email Address Redacted>>
www.progressivepo.com< <URL Redacted>>
9511 E. 46th St.
Tulsa OK, 74145
(918) 663 7077
YOUR LETTERHEAD
CMS directors, Stacey Brennan, MD, et al.
RE: Proposed LCD DL33787
Dear CMS Directors,
In regards to recent proposed changes in the CMS coverage of orthotics and prosthetics, Orthotists and Prosthetists have come together to unite with one voice for maintained coverage to CMS beneficiaries and reduction in overall cost of prosthetic care. We understand CMS Goals in cost containment, consolidation, and uniformity of care and want ultimately to reach these same goals in a way that is beneficial to the patient and fosters the development of new technologies to improve the health and lifestyle of every disabled American.
We humbly submit the following scenario as a solution:
1. We suggest that the draft LCD be rescinded, and code changes be delayed in order to allow Industry leaders, Amputee Advocates, and Prosthetic professionals to participate in a workable solution to reduce cost without negative impact to patient care.
2. We suggest that CMS permanently and finally separate Orthotic and Prosthetic devices and their respective L-codes from DME MAC. O&P care (with a very few exceptions) requires a highly trained professional to select and provide the necessary care to the patient. Orthotists and Prosthetists should be recognized as the LCMP that they are. Competitive bidding DME items should be placed under a separate coding structure, as these items require limited training or experience.
3. We suggest that an advisory board of prosthetic clinicians, amputees, and industry representatives be established to provide advice to CMS on consolidating coding, and coverage determination. Region C has already has such a board, the POE O & P advisory group, the membership is approved and consists of an optimal cross-section of clinicians, industry VIP's, and amputee advocates.
We further recommend CMS approve the Advisory Board to be a permanent voice to CMS practices and that the board have the following responsibilities to present a solution for Medicare coding structure now and in the future:
-Provide a proposal within a reasonable time frame for CMS to approve. We suggest 6-12 months
-Establish set quantifiable measures for defining K level
-Advocate for the patient
-Consolidate Prosthetic coding structures
-Establish updated base coding for each K level to include reimbursement of socket and component add on codes
Signed,
YOURNAMEHERE
YOUR LETTERHEAD
CMS directors
Attn: Stacey Brennan, MD
RE: Proposed LCD DL33787
Dear CMS Directors,
In regards to recent proposed changes in the CMS coverage of orthotics and prosthetics, Orthotists and Prosthetists have come together to unite with one voice for maintained coverage to CMS beneficiaries and reduction in overall cost of prosthetic care. We understand CMS Goals in cost containment, consolidation, and uniformity of care and want ultimately to reach these same goals in a way that is beneficial to the patient and fosters the development of new technologies to improve the health and lifestyle of every disabled American.
We have outlined three problematic areas of concern with the current LCD and the process that authored the proposed changes:
1. Proposed changes did not involve a panel of Certified or Licensed Orthotists/Prosthetists: CMS proposed changes and RAC audits have been carried out without peer review or proper understanding of the history of the services which are represented by the current coding system. We feel the lack of peer review in these changes is not in accordance with CMS policies and guidelines.
2. Repeatable Outcome Measures are not present to define K level or medical necessity: CMS has offered no repeatable measure for LCMP's to use to document a patient's K level. It has essentially been left up to subjective observation. In order to deem that services are or are not medically necessary CMS must offer a measurement of physical ability that is scientific and repeatable by the patient's therapist, physician, or prosthetist/orthotist.
3. Misunderstanding of Outdated Coding: We understand that CMS must cut unnecessary costs and that the current coding structure needs review. However, the current proposed LCD is insufficient in the provision of care that would be provided for patients. AOPA has laid out these concerns in the Executive Summary and summarized the negative impact to beneficiaries in detail:
4. http://www.aopanet.org/wp-content/uploads/2015/07/Proposed-Lower-Limb-Prosthesis-LCD-Summary-and-AOPA-Executive-Summary-for-Distribution-to-AOPA-Members.pdf
Proposal:
We humbly submit the following scenario as a solution:
1. We suggest that the draft LCD be rescinded, and code changes be delayed in order to allow Industry leaders, Amputee Advocates, and Prosthetic professionals to participate in a workable solution to reduce cost without negative impact to patient care.
2. We suggest that an advisory board of prosthetic clinicians and industry representatives be established to provide advice to CMS on consolidating coding, and coverage determination. Region C has already established a board of qualified, approved industry leaders, clinicians, and amputee advocates.
3. We suggest that CMS permanently and finally separate Orthotic and Prosthetic devices and their respective L-codes from DME MAC. O&P care (with a very few exceptions) requires a highly trained professional to select and provide the necessary care to the patient. Orthotists and Prosthetists should be recognized as the LCMP that they are. Competitive bidding DME items should be placed under a separate coding structure, as these items require limited training or experience.
We recommend that a CMS Advisory board be formed from the membership of the already established POE group for DME MAC Region C, as the membership is approved and consists of an optimal cross-section of clinicians, industry VIP's, and amputee advocates.
We recommend CMS approve the Advisory Board to be a permanent voice to CMS practices and that the board have the following responsibilities to present a solution for Medicare coding structure now and in the future:
-Provide a proposal within a reasonable time frame for CMS to approve. We suggest 6-12 months
-Establish set quantifiable measures for defining K level
-Advocate for the patient
-Consolidate Prosthetic coding structures
-Establish updated base coding for each K level to include reimbursement of socket and component add on codes
Signed,
YOURNAMEHERE
Citation
Jeff Arnette, “FW: Form letters,” Digital Resource Foundation for Orthotics and Prosthetics, accessed November 5, 2024, https://library.drfop.org/items/show/237575.
