AOTA Urges CMS Officials to Respect OT Practitioners in Supplier Quality Standards
OTs Called to Action!
AOTA met on November 7 with Centers for Medicare and Medicaid Services (CMS) officials to urge recognition of the distinct professional status of occupational therapists in applying new Supplier Quality Standards for durable medical equipment under Medicare.
However, CMS has put forward draft Supplier Quality Standards as required by the Medicare Modernization Act of 2003 for the provision of durable medical equipment, prosthetics, orthotics and supplies (DMEPOS), such as orthotics, canes, crutches and walkers—standards that would require providers/suppliers to be certified in orthotics and prosthetics from specific organizations, whether or not the health providers are already recognized by Medicare.
AOTA also elicited more information on CMS's current view on who must be subject to these additional quality requirements. Action by AOTA members and others is needed before the comment deadline of November 28. Tell CMS that occupational therapists already meet high standards as Medicare providers and should not need to obtain additional accreditation.
AOTA Defends Current Qualifications of OTs
During the meeting with CMS officials, AOTA firmly stated that a qualified occupational therapist under Medicare must already meet high standards for recognition as a Medicare provider, including education, certification and licensure, or other state regulation.
AOTA urged CMS to rely on the current requirements for occupational therapists to participate in Medicare as the quality standards for DME. Thus occupational therapists who supply orthotics (and other durable medical equipment such as canes and walkers) as part of a therapy plan of care should not have to obtain additional certification. AOTA strongly stressed that additional accreditation standards, specifically in this area, are not necessary for occupational therapists providing DMEPOS within a therapy intervention plan. AOTA also argued that additional credentials as proposed would not be relevant to other practitioners including physicians, podiatrists, and physical therapists.
CMS Discloses Possible Expanded Reach of the Proposed Standards
CMS also has disclosed to AOTA its current thinking about applying the Supplier Quality Standards to all Part B suppliers of DMEPOS, including not only occupational therapists in private practice, but physical therapists, physicians, CORFs, rehabilitation agencies, outpatient therapy clinics, hospitals and skilled nursing facilities who supply DMEPOS, regardless of whether these entities currently are required to obtain a DMEPOS supplier number from the National Supplier Clearinghouse (NSC). Occupational therapy practitioners can use this information to encourage rehabilitation colleagues and facilities to express concerns about the proposed supplier quality standards.
CMS also revealed to AOTA that although the draft Supplier Quality Standards currently addresses custom fabricated orthotics, CMS intends to ultimately devise standards for the full range of orthotics, including pre-fabricated orthotics.
Additional Facts About the Quality Standards
Comments to CMS are due on Monday, November 28. Furthermore, the comments that are due are ONLY on the quality standards.
CMS has yet to issue its proposed rule governing competitive bidding. CMS has not yet elicited feedback on competitive bidding from the public. The Quality Standards will be implemented separately from competitive bidding.
The basic issue is that CMS is considering requiring additional accreditation standards for all suppliers of orthoses, including occupational therapists. This does not mean that occupational therapists would no longer be allowed to provide any orthoses under Part B. AOTA is acting and urging your action to protect and promote the professional status of occupational therapists.
Take Action Now!
Armed with the additional information gleaned from AOTA's meeting with CMS regarding the Supplier Quality Standards, AOTA is calling on all occupational therapy practitioners to contact CMS now! Let CMS know how burdensome meeting these additional supplier standards will be for occupational therapists who provide occupational therapy services! On November 7, AOTA hand delivered its position statement on the quality standards to CMS. Use the statement to familiarize yourself with the issues and draft a letter before the comment period ends November 28.
Make the following important points to CMS:
- Occupational therapists who supply orthotics in the course of therapeutic intervention provide a full range of orthotic devices, not just those that are custom fabricated.
- Explain how the provision of orthotic devices is integral to and intertwined with occupational therapy treatment interventions and the devices are provided under Medicare requirements within an overall plan of care.
- Emphasize that the education, certification and licensure/regulation of occupational therapy practitioners currently required by Medicare is sufficient to assure quality in the provision of durable medical equipment as part of occupational therapy interventions.
- Describe the variety of types of patients you treat, including younger people with disabilities.
CMS will accept comments on the draft Supplier Standards until the close of business on Monday, November 28, 2005. View CMS's draft supplier quality standards, which were developed by Abt Associates.
Then, submit your concerns and comments to CMS directly (DMEPOS_Quality_Standards_Public_Comments@cms.hhs.gov).
AOTA will submit a formal comment letter in addition to having raised concerns in person at the November 7 meeting with CMS.