AAOE Members Secure Extended Comment Timeline for DMEPOS Proposal
Tuesday, November 27, 2018
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Posted by: Bradley Coffey, MA, AAOE Government Affairs
Indianapolis, IN - Members of the American Alliance of Orthopaedic Executives (AAOE) were instrumental in securing an extended public comment period on a proposal from the Centers for Medicare and Medicaid Services (CMS) to add off-the-shelf back and knee braces to the Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Competitive Bidding Program. For the past week, members have been sending letters to their members of Congress as well as CMS asking for an extension of the comment period and on Tuesday, November 27, CMS extended the deadline to December 17, 2018.
CMS' proposal would shift reimbursement for off-the-shelf back and knee braces from the current DMEPOS fee schedule to a reimbursement that is determined by competitive bidding. If this proposal is finalized, it would likely take effect when the Competitive Bidding Program resumes in December 2020.
In 2011, items included in the Competitive Bidding Program saw a reimbursement decrease of approximately 35%. If CMS adopts this proposal, physician suppliers and other suppliers of off-the-shelf back and knee braces could see their reimbursements tumble as much as 35%. The table below shows how these reimbursements could be affected for the codes identified by CMS as being moved to the Competitive Bidding Program assuming that they see a 35% reduction in their reimbursement value due to competitive bidding:
|
HCPCS Code
|
Description
|
DMEPOS Fee Schedule Ceiling for 2018
|
DMEPOS Fee Schedule Floor for 2018
|
Reimbursement Ceiling Under Competitive Bidding |
Reimbursement Floor Under Competitive Bidding |
|
L0450
|
Tlso, flex trunk/thor pre ots
|
$210.29
|
$157.72
|
$136.69 |
$102.52 |
|
L0455
|
Tlso flex trnk sj-t9 pre ots
|
$400.94
|
$300.70
|
$260.61 |
$195.46 |
|
L0457
|
Tlso flex trnk sj-ss pre ots
|
$1,149.77
|
$862.33
|
$747.35 |
$560.51 |
|
L0467
|
Tlso r fram soft pre ots
|
$452.08
|
$339.06
|
$293.85 |
$220.39 |
|
L0469
|
Tlso rig fram pelvic pre ots
|
$554.65
|
$415.99
|
$360.52 |
$270.39 |
|
L0621
|
Sio flex pelvic/sacr pre ots
|
$111.58
|
$83.69
|
$72.53 |
$54.40 |
|
L0623
|
Sio rig pnl pelv/sac pre ots
|
$0.00
|
$0.00
|
$0.00 |
$0.00 |
|
L0625
|
Lo flex l1-below l5 pre ots
|
$63.70
|
$47.77
|
$41.41 |
$31.05 |
|
L0628
|
Lso flex no ri stays pre ots
|
$97.00
|
$72.75
|
$63.05 |
$47.29 |
|
L0641
|
Lo rig pos pnl l1-l5 pre ots
|
$90.13
|
$67.60
|
$58.58 |
$43.94 |
|
L0642
|
Lo sag ri an/pos pnl pre ots
|
$475.32
|
$356.49
|
$308.96 |
$231.72 |
|
L0643
|
Lso sag ctr rigi pos pre ots
|
$187.26
|
$140.45
|
$121.72 |
$91.29 |
|
L0648
|
Lso sag r an/pos pnl pre ots
|
$1,187.06
|
$890.30
|
$771.59 |
$578.70 |
|
L0649
|
Lso sc r pos/lat pnl pre ots
|
$331.59
|
$248.69
|
$215.53 |
$161.65 |
|
L0650
|
Lso sc r ant/pos pnl pre ots
|
$1,356.89
|
$1,017.66
|
$881.98 |
$661.48 |
|
L0651
|
Lso sag-co shell pnl pre ots
|
$1,356.89
|
$1,017.66
|
$881.98 |
$661.48 |
|
L1812
|
Ko elastic w/joints pre ots
|
$119.17
|
$89.38
|
$77.46 |
$58.10 |
|
L1830
|
Ko immob canvas long pre ots
|
$105.86
|
$79.39
|
$68.81 |
$51.60 |
|
L1833
|
Ko adj jnt pos r sup pre ots
|
$735.65
|
$551.74
|
$478.17 |
$358.63 |
|
L1836
|
Ko rigid w/o joints pre ots
|
$154.26
|
$115.69
|
$100.27 |
$75.20 |
|
L1848
|
Ko dbl upright w/air pre ots
|
$664.92
|
$498.69
|
$432.20 |
$324.15 |
|
L1850
|
Ko swedish type pre ots
|
$348.30
|
$261.22
|
$226.40 |
$169.79 |
|
L1851
|
Ko single upright prefab ots
|
$1,037.28
|
$777.96
|
$674.23 |
$505.67 |
|
L1852
|
Ko double upright prefab ots
|
$989.01
|
$741.76
|
$642.86 |
$482.14 |
Some AAOE members also received a survey to provide more information on the use of off-the-shelf back and knee braces at their practices. This information is important to AAOE as we work to provide CMS with data on the potential impact of their proposed policy change. If you received a survey invitation in your email, we encourage you to fill it out and provide us with the information we need to effectively advocate for you.
If you are interested in providing comments on behalf of your practice, check out AAOE's Tips for Writing an Effective Comment Letter and email advocacy@aaoe.net to get assistance from AAOE staff in drafting and submitting your comments.
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