Post Mastectomy & CMS Qualified Provider Proposed Rule

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On January 12, 2017, the Federal Register published a rule proposed by the Centers for Medicare and Medicaid Services that defines the licensing, certification and accreditation requirements and qualifications needed for Orthotic & Prosthetic practitioners and suppliers who furnish and fabricate prosthetics and custom orthotics.  Further, the rule would enact provisions in the Social Security Act, which “requires that no Medicare payment shall be made for an item of custom-fabricated orthotics or for an item of prosthetics unless furnished by a qualified practitioner and fabricated by a qualified practitioner or a qualified supplier at a facility that meets criteria the Secretary determines appropriate.”

According to the proposed rule,  a qualified practitioner is someone who is

“licensed by the state, or in absence of licensure requirements is certified by the [ABC] or by the [BOC], or is credentialed and approved by a program that the Secretary determines, in consultation with appropriate experts in orthotics and prosthetics, has training and education standards that are necessary to provide such prosthetics and orthotics.”

Does any of this apply to post mastectomy?

yes and no.  On face value, probably not. however there are some strong concerns regarding conflicting language and definitions that AABCP staff is in the process of researching; the organization has requested clarification on several points.

 

The Executive Director of the American Association of Breast Care Professionals, Rhonda F Turner, states that

“It has always been AABCP’s mission to protect and give a voice to the post mastectomy professional.  Our greatest concern moving forward with this proposed rule is “unintended consequences” or broad interpretations of “prosthetics or qualified providers” that while not currently included,  could potentially and adversely effect post mastectomy providers.”

AABCP will be commenting on the Proposed Rule before the March deadline.

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Click Here to read the Federal Register: Proposed Rule