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AAPM&R Submits Proposed Rule Comments for Orthotics and Prosthetics

Mar 30, 2017

On March 14, AAPM&R submitted formal comments on the CMS Proposed Rule—Benefits Improvement and Protection Act of 2000 (BIPA 2000), Section 427; Special Payment Provisions for Custom-Fabricated Orthotics and Prosthetics in the Medicare Program; CMS-6012-P. We applauded CMS for publishing this long-awaited proposed rule and supported its goals of protecting patient care while protecting the Medicare program from waste, fraud, and abuse. While we had some recommendations to offer and some concerns to address in our comment letter, we supported the intent of the rule and urged CMS to publish it in its final form once several areas of concern have been addressed.

We emphasized that our members who focus on sports medicine and outpatient practice tend to provide an array of orthotic braces, splints, and durable medical equipment ancillary to their physician services. Our rehabilitation physicians have training and expertise in the prescription, management, and fitting of a wide range of orthoses for neurological, orthopedic and congenital conditions, and prostheses for individuals with limb amputations.