December 2014 O&P Almanac

The Magazine for the Orthotics & Prosthetics Profession

D E C E M B E R 2014

Exclusive! Medicare Code and Policy Changes for 2015 P.16

Update and Partnership Opportunities at the VA P.28

RAISING AWARENESS,

SECURING THE FUTURE CALIFORNIA BUSINESS OWNERS TAKE A STAND ON THE VITAL ISSUES SURROUNDING O&P

AOPA Announces New Leadership P.34

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CREDITS

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P.18

This Just In: Key Senate Members Weigh In on OTS Definition P.19

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DECE M B E R 2014 | VOL. 63, NO. 12

contents

FEATURES

DEPARTMENTS | COLUMNS

22

President’s View....................................... 4

Insights from AOPA President Charles H. Dankmeyer Jr., CPO

AOPA Contacts............................................6 How to reach staff

Numbers........................................................ 8

At-a-glance statistics and data

COVER STORY

Happenings............................................... 10

Research, updates, and industry news

People & Places........................................ 14

Transitions in the profession

22 | Raising Awareness, Securing the Future

Reimbursement Page.......................... 16

When California’s Medicare program set out to redefine a range of regulations related to O&P care, state-level experts and business owners sought to educate rulemakers on the critical issues surrounding quality patient care, reimbursements, and more.

By Adam Stone

19 | This Just In

P.20

CE Opportunity to earn up to 2 CE credits by taking the online quiz.

CREDITS

Member Spotlight................................ 30 n

Coyote Design Tillges Certified Orthotic Prosthetic, Inc.

AOPA News................................................ 34

P. 28

AOPA meetings, announcements, member benefits, and more

Welcome New Members ................... 41

28 | Primed for Partnership The VA provides a full spectrum of world-class prosthetic, orthotic, pedorthic, and rehabilitation services for veterans. Learn more about its efforts to standardize therapeutic footware and partnership opportunities for O&P professionals to provide care to veteran patients.

By Anthony Lazzarino, DPM

Preparation is key to successfully adjusting to the modifications

n

Key Senate Members Weigh In on OTS Definition Recent concerns expressed by Sens. Grassley and Harkin have helped strengthen and clarify the record of O&P challenging CMS for expanding the definition of OTS orthotic devices.

Medicare Changes for 2015: New Codes, New Opportunities

Marketplace............................................... 41

Careers.........................................................42

Professional opportunities

Calendar..................................................... 44

P. 34

Upcoming meetings and events

Ad Index....................................................... 47 Ask AOPA.................................................. 48 Expert answers to your questions about prescription writing and hospital payments

Advertise with Us! For advertising information, contact Bob Heiman at 856/673-4000 or email bob.rhmedia@comcast.net.

O&P ALMANAC | DECEMBER 2014

3

PRESIDENT’S VIEW

Welcoming New Leadership for 2015

T

HE BEAUTIFUL ASPECT OF AOPA’s leadership structure is the opportunity to still have the wisdom and the experience of those who have served as AOPA’s president for one additional year beyond their presidency, as they continue serving on the AOPA Executive Committee as immediate past president. Anita Liberman-Lampear’s year at the helm was a challenging and hectic period. It seems we went from RAC audit-related issues, to challenging the CMS off-the-shelf (OTS) list of devices eligible for competitive bidding, to a dozen or more other threats. Under Anita’s leadership, AOPA garnered significant patient support for opposing the CMS pre-authorization and the OTS challenges for the first time. Big thanks, Anita, and thank you for being around for another year.

More gratitude goes to four others who have served in the leadership role, starting with Tom Kirk, PhD, who leaves the board after completing his term as past president.

His leadership in confronting the future with tools we could provide members yielded the much-heralded Mobility Saves Lives and Money public awareness campaign.

What a legacy Tom has bequeathed to AOPA. Jim Weber, MBA, served as treasurer for five very financially challenging years as the O&P field and the AOPA member base shrunk from consolidations and painful business closings related to CMS audit practices. His success can be measured by the guidance he provided to keep AOPA in the black and our reserves at an appropriate level, which Jim fondly calls the “rainy day” fund.

Al Kritter, CPO, FAAOP, and Ron Manganiello also served their tours of duty and have retired from the board. Al always was our resident expert on the intricacies of CMS regulatory policies, coding, and other broad policy issues. Ron brought his years of O&P executive leadership to the board along with a wealth of common sense, a finger on the pulse of independent O&P practices, and policy direction.

Our new recruits will certainly pull their own weight in filling these gaping experience holes. Pam Lupo, CO, director of orthotics and manager of women’s care at Wright & Filippis, representing 6-30 facilities, has served more than 10 years with Al Kritter on AOPA’s Coding and Reimbursement Committee and has been one of the most knowledgeable speakers at AOPA National Assembly programs. Pam also is a facility accreditation surveyor for ABC. Jeffrey Lutz, CPO, central zone vice president of Hanger Clinic represents the 31+ facilities director position. He has a long and rich history in O&P as a practitioner and executive. Chris Nolan, vice president and general manager of Endolite, is a 15-year veteran of the O&P field and chairs the National Assembly Planning Committee. His first year out as chair of the Las Vegas 2014 event provided the kind of leadership that brought about innovations that were warmly embraced by both attendees and exhibitors.

Promotions from board service to the Executive Committee brings Jeff Collins, president and chief financial officer of Cascade Orthopedic Supply Inc., to the role of treasurer and Michael Oros, CPO, president of Scheck & Siress, to vice president of AOPA. This is the team that will help respond to your resounding affirmation of the three things we need to accomplish on behalf of O&P: protect our turf; have orthotists and prosthetists notes recognized as the source of O&P clinical need; and finally, be appropriately compensated for our services. With your help, we will move the needle big time on these important issues.

Charles H. Dankmeyer Jr., CPO, AOPA President 4

DECEMBER 2014 | O&P ALMANAC

Specialists in delivering superior treatments and outcomes to patients with limb loss and limb impairment.

Board of Directors OFFICERS

President Charles H. Dankmeyer Jr., CPO Dankmeyer Inc., Linthicum Heights, MD President-Elect James Campbell, PhD, CO, FAAOP Becker Orthopedic Appliance Co., Troy, MI Vice President Michael Oros, CPO Scheck and Siress O&P Inc., Oakbrook Terrace, IL Immediate Past President Anita Liberman-Lampear, MA University of Michigan Orthotics and Prosthetics Center, Ann Arbor, MI Treasurer Jeff Collins, CPA Cascade Orthopedic Supply Inc., Chico, CA Executive Director/Secretary Thomas F. Fise, JD AOPA, Alexandria, VA DIRECTORS Maynard Carkhuff Freedom Innovations, LLC, Irvine, CA Eileen Levis Orthologix LLC, Trevose, PA Pam Lupo, CO Wright & Filippis Inc., Rochester Hills, MI Jeffrey Lutz, CPO Hanger Clinic, Lafayette, LA Dave McGill Össur Americas, Foothill Ranch, CA Chris Nolan Endolite, Miamisburg, OH Scott Schneider Ottobock, Minneapolis, MN Don Shurr, CPO, PT American Prosthetics & Orthotics Inc., Iowa City, IA

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AOPA CONTACTS

American Orthotic & Prosthetic Association (AOPA) 330 John Carlyle St., Ste. 200, Alexandria, VA 22314 AOPA Main Number: 571/431-0876 AOPA Fax: 571/431-0899 www.AOPAnet.org

Publisher Thomas F. Fise, JD Editorial Management Content Communicators LLC

Our Mission Statement The mission of the American Orthotic & Prosthetic Association is to work for favorable treatment of the O&P business in laws, regulation and services; to help members improve their management and marketing skills; and to raise awareness and understanding of the industry and the association.

Our Core Objectives AOPA has three core objectives—Protect, Promote, and Provide.

These core objectives establish the foundation of the strategic business plan. AOPA encourages members to participate with our efforts to ensure these objectives are met.

EXECUTIVE OFFICES

O&P ALMANAC

Thomas F. Fise, JD, executive director, 571/431-0802, tfise@AOPAnet.org

Thomas F. Fise, JD, publisher, 571/431-0802, tfise@AOPAnet.org

Don DeBolt, chief operating officer, 571/431-0814, ddebolt@AOPAnet.org

Josephine Rossi, editor, 703/662-5828, jrossi@contentcommunicators.com

MEMBERSHIP & MEETINGS Tina Moran, CMP, senior director of membership operations and meetings, 571/431-0808, tmoran@AOPAnet.org Kelly O’Neill, CEM, manager of membership and meetings, 571/431-0852, koneill@AOPAnet.org Lauren Anderson, manager of communications, policy, and strategic initiatives, 571/431-0843, landerson@AOPAnet.org

Catherine Marinoff, art director, 786/293-1577, catherine@marinoffdesign.com Bob Heiman, director of sales, 856/673-4000, bob.rhmedia@comcast.net Christine Umbrell, editorial/production associate and contributing writer, 703/662-5828, cumbrell@contentcommunicators.com Lia K. Dangelico, contributing writer, ldangelico@contentcommunicators.com

Betty Leppin, manager of membership services and operations, 571/431-0876, bleppin@AOPAnet.org AOPA Bookstore: 571/431-0865 GOVERNMENT AFFAIRS Joe McTernan, director of coding and reimbursement services, education and programming, 571/431-0811, jmcternan@AOPAnet.org Devon Bernard, assistant director of coding and reimbursement services, education, and programming, 571/431-0854, dbernard@AOPAnet.org 6

DECEMBER 2014 | O&P ALMANAC

Advertising Sales RH Media LLC Design & Production Marinoff Design LLC Printing Dartmouth Printing Company SUBSCRIBE O&P Almanac (ISSN: 1061-4621) is published monthly by the American Orthotic & Prosthetic Association, 330 John Carlyle St., Ste. 200, Alexandria, VA 22314. To subscribe, contact 571/431-0876, fax 571/431-0899, or email almanac@AOPAnet.org.

Yearly subscription rates: $59 domestic, $99 foreign.

All foreign subscriptions must be prepaid in U.S. currency, and payment should come from a U.S. affiliate bank. A $35 processing fee must be added for non-affiliate bank checks. O&P Almanac does not issue refunds. Periodical postage paid at Alexandria, VA, and additional mailing offices.

ADDRESS CHANGES POSTMASTER: Send address changes to: O&P Almanac, 330 John Carlyle St., Ste. 200, Alexandria, VA 22314.

Copyright © 2014 American Orthotic and Prosthetic Association. All rights reserved. This publication may not be copied in part or in whole without written permission from the publisher. The opinions expressed by authors do not necessarily reflect the official views of AOPA, nor does the association necessarily endorse products shown in the O&P Almanac. The O&P Almanac is not responsible for returning any unsolicited materials.

All letters, press releases, announcements, and articles submitted to the O&P Almanac may be edited for space and content. The magazine is meant to provide accurate, authoritative information about the subject matter covered. It is provided and disseminated with the understanding that the publisher is not engaged in rendering legal or other professional services. If legal advice and/or expert assistance is required, a competent professional should be consulted.

Reimbursement/Coding: 571/431-0833, www.LCodeSearch.com

Advertise with Us!

MobilitySaves.org

Reach out to AOPA’s membership and 15,000 subscribers.

Engage the profession today. Contact Bob Heiman at 856/673-4000 or email bob.rhmedia@comcast.net.

Visit bit.ly/aopa14media for advertising options!

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NUMBERS

How Does Your Facility Compare to the Typical O&P Company?

AOPA recently published the 2014 Operating Performance Report, based on 2013 data, which captured the financial facts from 99 companies representing 1,116 full-time facilities and 71 part-time facilities.

YEARS IN BUSINESS

EMPLOYEE MAKEUP

32.3%

27 Years

Average amount of time facilities have been in operation.

36.7%

Office administration/marketing makes up the largest percentage of staff.

WEEKENDS HOURS?

89.1%

Less than 5% of all facilities are open on Saturdays.

Nine out of 10 companies use central fabrication to some extent.

7.1%

70.2%

A higher percentage of “profit leaders” are open on Saturdays.

A smaller percentage uses central fab when considering only those companies with more than $5 million in sales.

SALES & PROFITS More larger facilities participated in FY 2013— though net profits are down for all.

Participants by Company Size

Company Size $1 to $2 million

$2 million to $5 million Over $5 million

8

Net Profit Margin

FY2012 FY2013 FY2012 FY2013

Up to $1 million

6.5%

Owners (clinical and nonclinical) account for more than 5 percent of staff.

CENTRAL FAB

4.3%

Nonowner practitioners comprise the second largest segment of staff.

DECEMBER 2014 | O&P ALMANAC

21.5%

20.2%

9.1%

5.8%

34.4%

21.3%

5.6%

5.3%

28.0%

30.9%

5.8%

3.0%

16.1%

27.6%

6.6%

6.0%

“The report shows an unsurprising drop in key performance data. Net profit as a percentage of sales before taxes eased to 5 percent for all respondents in 2013 compared with 6.4 percent in 2012 and 6.1 percent in 2011.”

—“Numbers Don’t Lie,” O&P Almanac, November 2014, page 38.

Editor’s Note: The 2014 OPR is now available through the AOPA bookstore for members at $85 for the electronic version and $185 for the hard copy. The electronic version is also available to nonmembers for $185 and $325 for the hard copy. Visit www.aopanet.org.

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Happenings RESEARCH ROUNDUP

Paralyzed Man Walks After Cell Transplant A man who had been paralyzed from the chest down is walking again after undergoing a transplant of cells from his nasal cavity into his spinal cord. Poland’s Darek Fidyka, who was paralyzed in 2010 after a knife attack, underwent the first-of-its-kind treatment in Poland in collaboration with scientists in London.

Surgeons removed olfactory ensheathing cells (OECs)—cells that enable nerve fibers to be continually renewed and aid in the sense of smell— from one of Fidyka’s olfactory bulbs then grew them in a culture. Two weeks later, surgeons transplanted the OECs into Fidyka’s spinal cord. Doctors made approximately 100 micro-injections of OECs above and below the patient’s injury site. They also took four thin

Researchers Design Adaptive Interface for Prosthesis Comfort

10

DECEMBER 2014 | O&P ALMANAC

Haiying Huang, professor of mechanical and aerospace engineering

changes in the circumference of the residual limb during the day, and the water content in the tissue. The design is intended to reduce the discomfort, blistering, and ulcers prosthetic users experience between their prostheses

and their residual limbs due to volume changes throughout the day.

Leading the research team are Haiying Huang, professor in the mechanical and aerospace engineering department and an expert in sensor technology, and Muthu Wijesundara, principal research scientist at UT—Arlington’s Research Institute.

“Eventually, we want to build the socket that can adjust automatically to the patient,” Huang said. “To do that, we need the sensors to tell us when and how to adjust the socket. We plan to design a warning system first, then the sensor data will teach us how to adjust the interface automatically.”

This project is intended to improve prosthetic wear for soldiers injured in war as well as other amputees. The researchers say it could take three to five years to start clinical applications.

PHOTO: Courtesy of UT Arlington

The Department of Defense PeerReviewed Orthapaedic Research Program has awarded a $744,300 grant to researchers at the University of Texas—Arlington (UT—Arlington) to create an adaptive interface that fits between a prosthesis and a patient’s limb. The goal is to improve the fit and comfort of prosthesis use.

The UT—Arlington team is designing an interface that will resemble inflatable bubble wrap and will be embedded with sensors. Four types of sensors will be used with the interface to monitor the fitting of the prosthetic device.

The sensors will measure vertical movement of the limb relative to the socket wall, the pressure on the limb,

strips of nerve tissue from Fidyka’s ankle and placed them across an 8-mm gap on the left side of the spinal cord.

Three months post-transplant, after intensive physical therapy, Fidyka first noticed his left thigh begin to put on muscle. Six months post-surgery, he took his first steps along parallel bars, using leg orthoses. Two years post-treatment, he can walk using a frame. He also has recovered some bladder and bowel sensation.

Researchers say the OECs provided a pathway to enable fibers above and below the injury to reconnect, using the nerve grafts to bridge the gap in the cord. They hope to treat another 10 patients in Poland and Britain in the next few years. For details, see the October issue of Cell Transplantation.

HAPPENINGS

O&P OUTREACH CODING CORNER

PDAC Reclassifies Knee Orthoses

The Pricing, Data Analysis, and Coding contractor (PDAC) has sent an email notice to all manufacturers who have previously had PDAC coding verification for products described by L1843 and L1845. The notice informs manufacturers that the addition of codes K0901 and K0902, effective Oct. 1, 2014, which describe off-the-shelf (OTS) versions of L1843 and L1845, requires the PDAC to potentially reclassify products previously verified as L1843 or L1845 under the new OTS codes. The PDAC has requested that manufacturers review their list of PDAC-verified products and indicate whether each product is always delivered OTS, can be delivered either OTS or custom fitted, or is always delivered as custom fitted.

While individual manufacturers must make their own determination regarding the status of their products described by the codes in question, AOPA notes there are several important issues that must be considered when making this decision: PHOTO: O&P Outreach/William Stauffer, CPO

1. PDAC verification currently is only mandatory for knee orthoses described by L1845/K0902. There is no current requirement that knee orthoses described by L1843/ K0901 must be PDAC-verified as a condition for Medicare payment.

Only products described by L1843 that manufacturers have submitted voluntarily for PDAC verification must be reclassified.

2. CMS, in its response to comments on the initial list of proposed OTS orthotic codes, agreed with AOPA that L1843 and L1845 represent products that could not be expected to be fit in an OTS environment.

The release of the OTS versions of these codes directly contradicted CMS’s earlier comments. AOPA continues to address this issue with high-level CMS officials.

3. PDAC verification of products in the middle category, as devices that can be either custom-fitted or OTS, could well entail the DME MACs applying intense scrutiny to claims billed under the customfitted version of the split code set and may lead to unnecessary denials due to alleged missing or incomplete documentation of the specific medical need for a patient receiving the custom-fitted orthosis, as opposed to the receiving it OTS (and thereby without any fitting, alignment, or adjustment by a clinical professional).

4. Medicare reimbursement for OTS orthoses will almost certainly not remain level with custom-fitted versions of the same product.

Whether fee reduction is accomplished through future competitive bidding or an alternate method, CMS intends to significantly reduce reimbursement for OTS orthoses.

While a response to any communication from the PDAC regarding coding verification is asserted as mandatory, AOPA manufacturer members are encouraged to consider all of the issues at hand when generating their response.

For more information, contact Joe McTernan, AOPA’s director of reimbursement services, at jmcternan@aopanet.org.

Palestinian Girl Travels to U.S. for Prosthesis A 14-year-old Palestinian girl has travelled to the United States to be fit with her first prosthetic leg and is walking for the first time ever. Hebatallah Shaheen travelled to Raleigh, North Carolina, from Gaza in September to stay with a foster family and receive treatment from North Carolina Orthotics and Prosthetics (NCOPI) practitioner William Stauffer, CPO. Shaheen’s trip was coordinated by the Palestine Children’s Relief Fund, which secures free care for Middle Eastern children with severe medical needs. The organization worked on Shaheen’s behalf to organize travel, lodging, and needed medical equipment and care while in the United States.

NCOPI, a regional O&P facility with five locations throughout the state, provided fabrication and fitting services and is using donated prosthetic components from Freedom Innovations and Össur.

Shaheen is living with an Arabic-speaking family and will remain there until she gains proficiency walking. She says she is most excited to run and ride a bicycle when she returns to her family in Gaza. “We are honored to be a part of this transition in Hebatallah’s life,” says Stauffer. “She’s a bright young lady with a bright future, and we’re looking forward to seeing her through this process.

It never gets old helping someone walk for the first time.”

O&P ALMANAC | DECEMBER 2014

11

HAPPENINGS

O&P ATHLETICS

Double Amputee to Take Part in Yacht Race Brett Whiteley, an Australian man who lost his right arm and leg in a motorcycle accident last year, will compete in the 2014 Rolex Sydney Hobart Yacht Race in late December. The iconic Australian race is a 628-nautical mile course that often is described as the most grueling long ocean race in the world.

Whiteley is one of the state’s 19 ambassadors for the nonprofit Sailors With Disabilities campaign, and he hopes his adventure will change public attitudes toward people with a disability.

DECEMBER 2014 | O&P ALMANAC

OPAF’s First Cycle Clinic

More than 100 people attended the launch of OPAF’s First Cycle Clinic on October 4 in Greenville, South Carolina, making it the largest First Clinic ever. First Cycle offered adaptive cycling opportunities for children and adults facing physical or mobility challenges. The event was sponsored

by Ability Prosthetics & Orthotics, Shriners Hospital for Children/ Greenville, Roger C. Peace Rehab Hospital, Endolite, and Paceline, in partnership with Greenville Cycle and Multi Sport and Heather’s Ride.

Participants came from the Carolinas, Georgia, and Tennessee to try adaptive cycling. First Cycle was the brainchild

of John Kinder and Brian Kaluf, CP, of Ability Prosthetics, both avid cyclists.

They wanted to offer a chance for others to be introduced to cycling as part of their recreational activities.

During the event, participants rode handcycles, trikes, and tandem bicycles, specific to their challenge or injury.

Paralympic cyclists and coaches who had recently competed in the IFC Paracycling Championships in Greenville instructed and coached the participants.

“We are very proud of the collaboration efforts to bring First Cycle to life and look forward to introducing new First Clinics in 2015 with First Dash and First Safeguard,” says OPAF Executive Director Robin Burton.

PHOTOS:OPAF

12

OPAF Launches First Cycle in South Carolina

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PEOPLE & PLACES PROFESSIONALS ANNOUNCEMENTS AND TRANSITIONS

Tim Russo, CPO/LPO, has joined the Scheck & Siress Prosthetics patient-care facility in Lincoln Park, Illinois. Russo most recently worked at the Department of the Army’s Center for the Intrepid in San Antonio. He also has lectured and trained individuals in the areas of upper-extremity prosthetics and the Intrepid Dynamic Exoskeletal Orthosis.

William Smith, CO, has joined Lawall Prosthetics & Orthotics in Wilmington, Delaware. Smith previously worked in many hospitals in Pennsylvania, primarily with Magee Rehabilitation and Bryn Mawr Rehabilitation.

Wendy Fischl Beattie, CPO, FAAOP

Wendy Fischl Beattie, CPO, FAAOP, has been named the new program director and clinical coordinator of Eastern Michigan University’s (EMU’s) graduate program in orthotics and prosthetics. Beattie brings more than 25 years of experience in private practice to EMU’s program.

Prior to joining EMU, Beattie served as residency director and clinical education coordinator for Becker Orthopedic, where she was responsible for overseeing O&P residents and arranging continuing education for practitioners.

Frank S. Daniels, CPed, CO, BOCP, has joined the Scheck & Siress Prosthetics patient-care facility in Schererville, Indiana. Daniels brings advanced training in cranial remolding, WalkAide, Ottobock C-leg, myoelectric devices, diabetic foot care, Lyons orthoses, Insignia training, and pediatric O&P. Vikki Donovan, the purchasing manager/orthotist for Orthotic & Prosthetic Lab of Webster Groves, Missouri, has retired after more than 31 years at the facility. Donovan practiced as an ABC-certified orthotist for many years before becoming purchasing manager.

Lizz Peterson, CPO, has joined the Scheck & Siress Prosthetics patient-care facility Vikki Donovan in Schaumburg, Illinois, and will specialize in pediatric orthotics. Peterson received her certificate in orthotics and prosthetics from California State University—Dominguez Hills and completed orthotic and prosthetic residencies at Westcoast Brace & Limb in Tampa, Florida.

14

DECEMBER 2014 | O&P ALMANAC

Hanger Clinic has announced the hiring of more than 30 practitioners: • Janis Baker, CPed, and Melissa Turncliff, CP, at the Albuquerque patient-care clinic • Rachel Barness, CPO, at the Baxter, Minnesota, patient-care clinic • Christopher Bossier, CO, at the Covington, Louisiana, patient-care clinic • Catherine Braun, CP, at the Kalamazoo, Michigan, patient-care clinic • KC Carlson, CPO, at the Fort Collins, Colorado, patient-care clinic • Hector Casanova, CPO, and Jeff Wehrs, CPed, at the San Jose, California, patient-care clinic • Marcus Day, CPed, at the Rogers, Arkansas, patient-care clinic • Aimei Deng, CPed, at the Newport Beach, California, patient-care clinic • Allison Elan, CO, at the Los Angeles patient-care clinic • Jennifer Gatson, CO, at the Greenbelt, Maryland, patient-care clinic • Bryan Gerhard, CP, at the Riverside, California, patient-care clinic • George Henderson, CPO, at the York Pennsylvania, patient-care clinic • Jody Huwyler, CO, at the Bartlesville, Oklahoma, patient-care clinic • Ashley Mullen, CPO, at the Houston patient-care clinic • Hema Patel, CO, at the Maryville, Tennessee, patient-care clinic • Robert Polander, clinic manager at the Lynchburg, Virginia, patient-care clinic • Adrian Ravitz, clinic manager at the Livermore, California, patient-care clinic • Steven Rutledge, CO, at the Enid, Oklahoma, patient-care clinic • Robert Sack, CP, at the Tucson, Arizona, patient-care clinic • Angela Shah, CO, at the Santa Fe, New Mexico, patient-care clinic

PEOPLE & PLACES

• Todd Smith, CPO, at the Oklahoma City patient-care clinic • John Snapp, CPO, at the Portland patient-care clinic • Peter Spilka, CPO, at the Farmington, Connecticut, patient-care clinic • Amanda (Amy) Street, CPO, at the Charlotte, North Carolina, patient-care clinic • Ryan Threm, CPO, at the Montrose, Colorado, patient-care clinic • Bob Tschida, clinic manager, at the Carson City, Nevada, patient-care clinic • Anthony Ung, CPO, at the Orange, California, patient-care clinic • Kristopher Urbanovitch, CPO, at the Cumming, Georgia, patient-care clinic • Bernard Watson, CPO, at the San Antonio patient-care clinic • George Wilkinson, CO, and Laake Hiruy, CPO, at the Philadelphia patient-care clinic • Michele Williams, CO, at the Florissant, Missouri, patient-care clinic

AOPA has become a Silver Level Sponsor for OPAF for 2015. AOPA was one of the founding sisters of OPAF back in 1995. “This financial support will mean further development of more introductory-level adaptive recreation for those facing physical and/or mobility challenges,” says Robin Burton, OPAF executive director. “The First Clinics are meeting a need for increased mobility and activity for the population that we all serve.”

From left to right, Steven Gordon, Elizabeth Ginzel, Rita Patterson, Katelyn Rockenbach, Nicoleta Bugnariu, Carolyn Young, Jordan Davis, and Michael Serrano

BUSINESSES ANNOUNCEMENTS AND TRANSITIONS

The Amputee Coalition has become an integrated supplier within the OPIE Software system and at www. oandp.com/shop. This technological integration allows OPIE software users and visitors to www.oandp.com to view and place electronic orders for the available resource guides and patient education materials provided by the Amputee Coalition.

Amputee Prosthetic Clinic in Macon, Georgia, hosted 21 occupational therapy students from Middle Georgia College in Cochran, Georgia, for their annual field trip.

Jim Young, LP, CP, FAAOP, offered the students a basic introduction into upper-limb amputation/prosthetics.

The staff from Baker Orthotics and Prosthetics and researchers from the University of North Texas Health Science Center, were recognized for their research paper, “Functional Performance and Evaluation of Dynamic Response Feet.” The collaborative teams were honored with the prestigious Thranhardt award during the 2014 AOPA National Assembly in Las Vegas.

Curbell Plastics Inc. has acquired O&P Enterprises Inc. in Gurnee, Illinois. The facility has become one of Curbell’s 17 sales and distribution facilities located throughout the United States. Curbell has retained current management and employees.

Orthomerica has received FDA 510(k) clearance to manufacture cranial helmets using smartphone technology. The company offers U.S. FDA 510(k) cleared image capture devices for manufacturing of STARband and STARlight Cranial Orthoses. The system is currently available for cranial orthoses ordered directly from Orthomerica.

O&P ALMANAC | DECEMBER 2014

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REIMBURSEMENT PAGE

By JOE MCTERNAN

Medicare Changes for 2015: New Codes, New Opportunities Adjust your business strategy to prepare for modifications in coding and CMS policies Editor’s Note—Readers of CREDITS Reimbursement Page are now eligible to earn two CE credits.

After reading this column, simply scan the QR code or use the link on page 18 to take the Reimbursement Page quiz. Receive a score of at least 80 percent, and AOPA will transmit the information to the certifying boards.

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DECEMBER 2014 | O&P ALMANAC

A

S WE APPROACH THE final weeks

of 2014, it’s time to take a look into the future. 2015 promises to be an active year for changes in the way O&P services are delivered to Medicare patients.

Whether it is the creation of new Healthcare Common Procedure Coding System (HCPCS) codes, modification of existing codes, the possible introduction of prior authorization, or potential competitive bidding of off-the-shelf (OTS) orthoses, preparation is the key to successfully adjusting to new and challenging areas in the arena of O&P reimbursement.

This month’s Reimbursement Page will provide an overview of the changes that have already occurred as well as some of the changes that may be on the horizon for 2015.

2015 HCPCS Codes Update

In November, CMS released the annual update to the HCPCS code set. While there were not a lot of changes to the L codes that describe O&P services, the changes that were made may have a significant impact on your O&P business.

As part of its annual HCPCS update, CMS memorialized two new K codes that were effective for dates of service on or after Oct. 1, 2014. K0901 and K0902 were introduced to describe OTS versions of single (K0901) and double (K0902) upright knee braces that have traditionally been described

by L1843 and L1845, respectively.

The introduction of the two K codes to describe OTS versions of these orthoses, typically used to treat osteoarthritis, was of particular interest to AOPA as it signified a reversal of philosophy on the part of CMS. The original list of orthotic codes that CMS believed could be fit in an OTS environment included both L1843 and L1845. After reviewing substantial comments from AOPA, including several clinical articles that described the need for specific expertise and training to properly fit these orthoses, CMS agreed that orthoses used to treat osteoarthritis should never be delivered as OTS orthoses.

The subsequent release of K0901 and K0902 is a clear reversal of the early decision by CMS. AOPA has engaged high-level CMS officials regarding this apparent discrepancy and will continue its efforts to ensure that Medicare beneficiaries are not exposed to further injury through the improper treatment of osteoarthritis using OTS orthoses.

Another new L code, L6026, has

REIMBURSEMENT PAGE

been established and is eligible for claims with a date of service on or after Jan. 1, 2015. This code replaces L6025, which will be deleted from the HCPCS list as of Dec. 31, 2014.

The reason for the creation of L6026 and deletion of L6025 is to allow prosthetic providers the opportunity to better describe partial hand prostheses that utilize myoelectric control. L6025 included a terminal device in its descriptor and did not allow for the proper addition of different styles of terminal devices that are appropriate for the specific clinical needs of the patient.

The creation of L6026, which specifically excludes a terminal device, allows the prosthetic provider to independently report the features of the partial hand base code and the unique features of the specific terminal device that best suits the clinical needs of the patient.

AOPA supported this decision during the HCPCS public meeting in May and believes that it will be beneficial to both the Medicare program as well as the provider community.

L3981 has been established, effective for dates of service on or after Jan. 1, 2015, to describe a prefabricated upper-extremity fracture orthosis that incorporates a shoulder cap into its design. The creation of this code fills a gap in the existing coding system that had previously established L codes

1, 2015. L7259 replaces L7260 and L7261, which will be deleted from the HCPCS list as of Dec. 31, 2014. The change represented by the creation of L7259 and subsequent deletion of L7260 and L7261 is consistent with CMS’s philosophy to move away from specific brand references within the

The reason for the creation of L6026 and deletion of L6025 is to allow prosthetic providers the opportunity to better describe partial hand prostheses that utilize myoelectric control. for prefabricated fracture orthoses at the wrist, forearm, and upper-arm levels, but not to the level of the shoulder. Once again, AOPA supports the addition of this code as it creates a more complete coding system.

The final new code for 2015 is L7259, which is effective for claims with a date of service on or after Jan.

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coding system and does not represent a significant change to the proper description of electronic wrist rotators.

The only L code that had a descriptor change for 2015 is L7367, which is used to describe the replacement of a lithium ion battery in a powered prosthesis. For 2015, the term “rechargeable” has been added to the descriptor for L7367.

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The Trowbridge Terra-Round foot mounts directly inside a standard 30mm pylon. The center stem exes in any direction allowing the unit to conform to uneven terrain. It is also useful in the lab when tting the prototype limb.

The unit is waterproof and has a traction base pad.

O&P ALMANAC | DECEMBER 2014

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REIMBURSEMENT PAGE

This change was made to ensure that providers are not using L7367 to describe disposable lithium ion batteries in powered prostheses.

prior-authorization proposed rule is available at www.aopanet.org.

While CMS has yet to release the final rule regarding its proposed expansion of its prior-authorization program, AOPA expects it to be published sometime during 2015, with implementation occurring within 60 days of the release of the final rule.

Proposed Prior Authorization

2015 will most likely bring developments related to CMS’s proposal to include certain lower-limb prosthetic HCPCS codes in a prior-authorization program.

CMS announced its intent to subject these codes to prior authorization in a proposed rule that was published in the Federal Register on May 28, 2014.

The proposed rule referenced the ongoing demonstration project relating to prior authorization of durable medical equipment power mobility equipment (power wheelchairs) and indicated that CMS intended to expand its prior-authorization authority by implementing a prior-authorization process for durable medical equipment prosthetics, orthotics, and supplies (DMEPOS) items that are frequently subject to unnecessary utilization or a high improper payment rate as established by the Office of the Inspector General or error rates reported by the Comprehensive Error Rate Testing contractors and that have an average purchase fee of $1,000 or greater or an average rental fee schedule of $100 or greater per month.

In the proposed rule, CMS included a “master list” of DMEPOS items that CMS believed are subject to prior authorization. This list contained 89 lower-limb prostheses codes. Inclusion of a code on the master list does not guarantee that it will be subject to prior authorization. CMS suggested that it would initially limit the number of items that require prior authorization to a subset of items chosen from the master list. While this initial subset was not indicated in the proposed rule, CMS stated that once the subsets of items are chosen, they would be published in the Federal Register and will include a 60-day comment period prior to implementation.

AOPA and its members provided extensive comments to CMS regarding potential flaws in the proposed rule as well as specific provisions that 18

DECEMBER 2014 | O&P ALMANAC

Competitive Bidding of OTS Orthoses

2015 will most likely bring developments related to CMS’s proposal to include certain lower-limb prosthetic HCPCS codes in a prior authorization program.

AOPA believes must be incorporated into the final rule before prior authorization can be considered palatable for the O&P community. These provisions included the following: • Claims that receive prior authorization must not be denied for nontechnical reasons when the actual claim is submitted.

• The immediate cessation of all postpayment review and Recovery Audit Contractor audit activity for any prosthetic L codes subject to prior authorization.

• Recognition of the prosthetist’s clinical notes as part of the patient’s medical record as they pertain to justification of medical necessity and claim payment.

• Reduced processing time for prior-authorization requests and resubmissions.

• A higher dollar threshold for prosthetic L codes subject to prior authorization.

A copy of AOPA’s extensive comments to CMS regarding the

Another issue that is expected to be in play in 2015 is the potential for inclusion of OTS orthoses in the Medicare competitive bidding program. The creation of specific OTS orthotic codes as well as the establishment of 25 “split codes” in 2014 that describe either custom-fitted or OTS versions of the same device signaled CMS’s intent to include OTS orthoses in future competitive bidding programs.

While the timeline for the existing competitive bidding programs may delay the inclusion of OTS orthoses in competitive bidding until late in 2015 or possibly into 2016, it is clear that the question is no longer if OTS orthoses will be competitively bid but rather when they will be competitively bid. It is important to review your business practices today and determine what specific impact this program may have on your business and what changes will be necessary to protect it.

The year 2015 looks to be a very active 12 months for the O&P community. Depending on how you view it, it will be either a year of challenges or a year of opportunity.

Joe McTernan is director of reimbursement services at AOPA. Reach him at jmcternan@aopanet.org.

Take advantage of the opportunity to earn two CE credits today! Take the quiz by scanning the QR code or visit bit.ly/OPalmanacQuiz.

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www.bocusa.org

This Just In

Key Senate Members Weigh In on OTS Definition Iowa legislators strengthen AOPA’s position by penning letter to CMS

S

ENS. CHARLES GRASSLEY (R-IOWA)

PHOTOS: www.wikimedia.org

and Tom Harkin (D-Iowa) are two of the most influential and long-standing members of the U.S. Senate. Grassley is the second ranking minority member of the Senate Finance Committee as well as the second ranking minority member of the Senate Budget Committee. Harkin is chairman of the Senate Health, Education, Labor, and Pensions Committee and the third ranking majority member of the Senate Appropriations Committee.

They rank third and fourth, respectively, in order of their party’s seniority and are two of the most highly regarded members of the U.S. Senate, particularly in terms of their impact on Medicare and CMS. That’s why the joint bipartisan letter from Oct. 15, 2014, to CMS Administrator Marilyn Tavenner signed by both senators taking CMS to task for expanding the definition of off-the-shelf (OTS) orthotic devices far beyond the words and intent of the statutory definition is so important to O&P.

Sen. Charles Grassley (R-Iowa)

The merits of the letter were advanced by AOPA and its lobbying team in early January 2014, initially through a series of meetings with several Senate offices. However, the contribution by Don Shurr, CPO, PTO, made a huge difference. He invited several of his Iowa colleagues to join him in communicating directly to both senators the tragedy of CMS’s medical necessity policies and how these horrors could easily proliferate from prosthetics to the overly aggressive list of OTS devices and split codes that CMS had concocted with potential adverse impact on Medicare beneficiaries. While the AOPA effort that ultimately resulted in this specific letter began in February 2014, AOPA challenges to CMS expanding

Sen. Tom Harkin (D-Iowa)

the OTS definition have gone on for several years.

No words were minced when the letter from Grassley and Harkin said, “It is our understanding that CMS ventured beyond both the language and the intent of the Medicare Modernization Act, Section 302, when on April 10, 2007, CMS published a final rule that, inter alia, defines ‘minimal self-adjustment’ to mean ‘an adjustment that the beneficiary, caretaker for the beneficiary, or supplier of the device can perform and does not require the services of a certified orthotist (that is, an individual certified by either the American Board of Certification in Orthotics, Prosthetics, and Pedorthics or the Board of Certification/Accreditation) or an individual who has specialized O&P ALMANAC | DECEMBER 2014

19

This Just In

training. As a result of this expansion from the statutory definition, we are concerned about the quality of care that beneficiaries will receive.”

Both senators were in Congress in 2003 when the Medicare Modernization Act was enacted, so they could speak authoritatively about what Congress intended when it enacted the criteria of “minimal self-adjustment” to narrowly define OTS orthotics.

This is the argument AOPA has been making since CMS first started expanding the definition. When rumors circulated among legislative staffers that CMS had identified some 200 orthotic devices that it considered “off-the-shelf ” eligible for competitive bidding, CMS ultimately released a list after receiving a request from the O&P Alliance. The initial list of 62 devices was published on the CMS website in February 2012 and subsequently was reduced to 55 devices in August 2013. AOPA, in a matter of a few days following release

of the initial list, pulled together a 479-page analysis, including scientific literature and other evidence to support AOPA’s view that only 13 of the devices clearly met the statutory definition of “minimal self-adjustment” by the patient.

The issue of OTS versus custom fit underwent further confusion with the publication of the 2014 revisions by the Healthcare Common Procedure Coding System in November 2013, which included a set of 23 orthotic codes that CMS exploded into two code sets of devices that could be treated as either custom fit or OTS. The catch 22 may be that, for now, these codes carry the same reimbursement regardless of service provided.

Earlier this year, CMS further expanded the definition when its contractors, the durable medical equipment Medicare Administrative Contractor (DME MAC) medical directors, added a new standard— “substantial modification.” Unless a

device requires substantial modification, the DME MACS will maintain that it will be considered an OTS device. This action led to AOPA writing a letter to Laurence Wilson, director of the Chronic Care Policy Group for CMS, on April 2, 2014, to challenge the new and expanded definition. The O&P Alliance followed up with its own letter to the DME MACs on April 29, 2014, voicing similar concerns.

Back in January, AOPA’s board adopted a three step-process to challenge the expanded definition and exploded codes, which included the following: 1. Educating members about the new codes and how they might be used, and urging members who provide clinical services to use the customfitted code, even though CMS has removed any reason to code as custom-fitted versus OTS because reimbursement is the same.

2. Encouraging a multidisciplinary task force including physicians,

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This Just In

therapists, and orthotists to look at the OTS situation and address issues relating to documentation, need for custom-fitting/clinical care, as well as the continuity of care for these orthotic patients as they move through the three health professional groups who typically make up the mobility team for orthotics patients. This group has met, researched, developed, and signed off on a white paper providing guidelines on orthotic provision of care, which has been submitted for publication in a peer-reviewed journal with the hope of establishing clarity as to which devices can be provided OTS and which need to be provided with custom-fitting by a certified/licensed health professional.

3. Encouraging and assisting in the development of a patient voice relating to devices that CMS insists on categorizing as OTS orthotics. Fortunately, the patient voice was mobilized when CMS

proposed regulations that sought to embrace the expanded statutory OTS definition eligible for competitive bidding, coupled with a limitation of the credentialed/licensed orthotic fitter’s role in providing custom-fitted orthoses. A total of 581 comments were filed by the Sept. 2, 2014, comment deadline on the proposal, including 203 patient comments and 378 letters from members. Several other organizations, in addition to AOPA, separately filed comments challenging the proposed regulation.

The letter from Grassley and Harkin to Tavenner hit the mark in instructing CMS that it needs to take two steps to remedy its errors on OTS, both of which are consistent with AOPA’s long-term concerns, with the following statement: “In order to ensure that beneficiaries receive quality orthotics and related services and avoid beneficiary harm,

The Source for Orthotic & Prosthetic Coding

we would request that CMS consider: 1) revising the regulatory definition of off-the-shelf orthotics in 42 C.F.R. part 14.402 to confirm with the statutory definition recognizing the clear meaning and limitation of ‘minimal self-adjustment’‘ and clarifying that this does not include adjustments either by a caretaker or by unregulated suppliers; and 2) modifying the OTS list and codes to eliminate from that list any device which does not meet fully and unambiguously the statutory definition of OTS orthotics including ‘minimal self-adjustment.’

Furthermore, we encourage you to work with AOPA and the O&P Alliance when establishing the new list of OTS devices that meet standards set by regulatory definition.”

The record of challenging CMS on the OTS definition has become clearer and much stronger as a result of the concerns and commitment expressed in this letter by these two senior members of Congress.

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O&P ALMANAC | DECEMBER 2014

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COVER STORY

RAISING AWARENESS,

SECURING THE FUTURE GOLDEN STATE BUSINESS OWNERS AND PRACTITIONERS TAKE ON PROPOSED MEDICARE CHANGES THAT COULD AFFECT O&P’S ABILITY TO PROVIDE TIMELY AND APPROPRIATE CARE E

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DA

A By

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DECEMBER 2014 | O&P ALMANAC

O ST

COVER STORY

Need to Know: Officials of California’s Medicare program (Medi-Cal) have proposed new regulations that could impact the care of O&P patients as well as jeopardize practitioner reimbursement. As the voice of California O&P, COPA brought experts to a recent Medi-Cal public hearing to help raise rulemakers’ understanding of O&P patient care.

COPA is concerned that Medi-Cal’s proposal would significantly widen the scope of a pharmacist’s participation and potentially put sensitive aspects of medical care into the hands of persons neither trained nor certified in the delivery of such care.

In a medical environment in which O&P work is too often misunderstood, COPA and its allies are especially concerned about changes that could undermine the professional status of practitioners.

COPA also is concerned that Medi-Cal has suggested that clinical notes be presented to document the medical necessity of a procedure or service.

This would not only delay the prior-authorization process and O&P care for beneficiaries but also negatively impact the reimbursement timeline.

Medi-Cal is expected to continue its deliberations into the spring. In the meantime, COPA officials say they are tentatively optimistic that their extensive input on the relevant proposals will be given serious weight.

E

STABLISHED IN 1970, THE California Orthotic

& Prosthetic Association (COPA) is the only statewide association dedicated to O&P business owners, individual practitioners, and patients. Members are medical professionals trained and certified to fabricate and fit O&P devices to patients as prescribed by an appropriately licensed health-care provider.

So when California’s Medicare program (Medi-Cal) set out to redefine a range of regulations related to O&P care, COPA spoke up loud and clear. As the voice of California O&P, the organization brought a bevy of experts to a recent Medi-Cal public hearing, in an effort to help raise rule makers’ understanding of the vital issues surrounding O&P patient care.

To set the stage: Medi-Cal officials have proposed a new range of regulations that could have a profound

impact on the care of amputees and other O&P patients. These same rules could jeopardize practitioner reimbursement, potentially straining to the breaking point many in the O&P community who already are challenged to practice their profession by RAC audits and other economically repressive practices.

While it’s important to look at the specific changes Medi-Cal has in mind (and we will do so later) it is equally important to understand the big picture. In many cases, these changes are misguided and potentially hazardous.

Often, they are downright nonsensical.

“We need to be crystal clear about what any new requirements are, because we are going to have to advise our membership on how best to comply. And yet in many cases there are omissions here you could drive a Mack truck through,” says Bryce Docherty, COPA executive director and lobbyist.

O&P ALMANAC | DECEMBER 2014

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COVER STORY

OTS at the National Level The issue of off-the-shelf orthotics (OTS) has been a very active one in recent months. Last year, CMS published an expansive list of OTS devices, largely ignoring medical evidence and documentation provided by AOPA in an effort to stake out the largest possible framework for any eventual OTS competitive bidding, despite the fact that Medicare beneficiaries’ health would be put in jeopardy because indispensable professional clinical fitting and adjustment to match the patient’s anatomical features would be eliminated.

This year, CMS published a proposed rule seeking to regulate both OTS devices and custom-fitted orthotic devices, and who can provide the needed fitting services.

On October 15, after substantial consultation with AOPA, Sens. Charles Grassley (R-Iowa) and Tom Harkin (D-Iowa) wrote the CMS Administrator criticizing CMS’ efforts to massively expand both the clear statutory term “minimal selfadjustment” (which defines OTS devices that are the only orthoses authorized for competitive bidding) and the category of OTS devices, instructing the agency: In order to ensure that beneficiaries receive quality orthotics and related services and avoid beneficiary harm, we would request that CMS consider: (1) revising the regulatory definition of off-the-shelf orthotics in 42 C.F.R. § 414.402 to conform with the statutory definition, recognizing the clear meaning and limitation of “minimal self-adjustment” and clarifying that this does not include adjustments either by a caretaker or by unregulated suppliers; and (2) modifying the OTS list and codes to eliminate from that list any device which does not meet fully and unambiguously the statutory definition of OTS orthotics including “minimal self-adjustment.” (Emphasis added) Furthermore, we encourage you to work with the American Orthotic and Prosthetic Association (AOPA) and the Orthotic and Prosthetic Alliance when establishing the new list of OTS devices that meet standards set by regulatory definition.

Interest and concern has continued as more legislators have followed Grassley and Harkin in challenging CMS about its actions relating to OTS orthotics. New data reveals that roughly 20 percent of the patients who receive a Medicare-reimbursed OTS device subsequently also receive a Medicarereimbursed custom-fitted device. In addition, AOPA has been in discussions with legislators about adding new language that would further clarify “minimal self-adjustment by that individual (and not by another person).”

More activity on this critical issue awaits. Read more about Sens. Harkin and Grassley’s letter to CMS on page 19.

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DECEMBER 2014 | O&P ALMANAC

The Pharmacists’ Role

Of greatest concern are the proposed changes to the role of the pharmacist in the chain of O&P care giving. While the pharmacist’s role has been welldelineated in recent times, Medi-Cal’s proposal would significantly widen the scope of a pharmacist’s participation.

These changes potentially put sensitive aspects of medical care into the hands of persons neither trained nor certified in the delivery of such care.

“We don’t want to kick the barn door open and have pharmacists become de facto O&P providers,” Docherty says. “Clearly you don’t want pharmacists being the provider of record, delivering customers’ orthotic or prosthetic devices.”

In legalese, the proposed changes amend codes in the Medi-Cal provider manual, potentially revising the range of O&P devices and services that licensed pharmacists and pharmacies may furnish. COPA asks: Are these codes consistent across different rules?

Does the state Department of Health Care Services plan on changing certain codes? Does the department even have statutory authority to include “a licensed pharmacist” in these rules?

These points may sound pedantic, but they go to the heart of COPA’s basic concerns: What exactly is being proposed here? It’s hardly clear, and yet the changes could come with profound ramifications.

In written statements, COPA indicated its concern that pharmacies would be authorized to furnish customized O&P devices, when in reality only O&P providers have the unique education and training to appropriately fit, fabricate, and furnish them.

If existing law would be expanded to include “a licensed pharmacist,” COPA argues, any such legislation also should include a requirement that such pharmacists be certified in orthotics or prosthetics by either the Board of Orthotist Certification or the American Board of Certification in Orthotics and Prosthetics.

COVER STORY

From left to right: Bryce Docherty, COPA executive director and lobbyist; Matthew Garibaldi, CPO, COPA vice president; Brandon Dale, CPO, COPA board member; Bob Jensen, CPO, COPA board member; Harry “JR” Brandt, CO, COPA board member; and Jeff Collins, CPA, COPA president, AOPA board member

There is background here.

Pharmacies are positioning themselves to bill Medicare for off-theshelf orthotic (OTS) devices under Medicare’s competitive-bidding scheme. The proposed changes in Medi-Cal could open the door still further, expanding the pharmacist’s role beyond that of OTS provider.

“The major concern coming out of this is that pharmacists could be considered qualified providers for all orthotic and prosthetic products, not just limited to off-the-shelf items,” says Brandon Dale, CPO, COPA board member, regional vice president at Hanger Clinic. “I am not sure we really care whether they are positioning themselves for competitive bidding [on durable medical equipment]. We don’t really care if pharmacists and pharmacies want to participate in OTS orthotic items.

But, we believe it is quite dangerous for any accrediting body to recognize pharmacists as qualified providers for all DMEPOS items.”

COPA Board Member Harry Brandt sees gaping holes all over the proposed change. While Medi-Cal would expand the scope of services offered by pharmacists, the legal language is unclear as to what those services might entail.

However it may be defined, the change

clearly would put inappropriate authority in the hands of untrained providers. “The fact that you have a ‘Pharm.D’ behind your name should not grant you access to the things other people are specifically trained to provide,” Brandt says. “A pharmacist is not going to have that body of knowledge to be able to provide that for that patient.”

“We believe it is quite dangerous for any accrediting body to recognize pharmacists as qualified providers for all DMEPOS items.”

—BRANDON DALE, CPO In tandem with the issue of professional competence is the larger question of professional standing. In a medical environment in which O&P work is too often misunderstood, COPA and its allies are especially concerned about changes that would seem to undermine the professional status of our practitioners. “We work really hard with therapists and physicians and patients to come up with a particular outcome,” says Brandt. “This would clearly diminish our stance in the rehab community.”

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COVER STORY

Keeping the Records

The issue of recordkeeping overlaps a wider ongoing concern in the O&P community.

Even as Medicare entities are calling for greater emphasis on note-taking, it remains unclear whether an O&P practitioner’s notes can even be included as part of the medical record.

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DECEMBER 2014 | O&P ALMANAC

While the status of pharmacists set off the loudest alarm bells in MediCal’s proposed changes, a number of other suggestions also have triggered concern among O&P practitioners.

One of these involves the matter of record keeping, which Medi-Cal has suggested be tied more closely to prior authorization.

Specifically, it is proposed that clinical notes be presented to document the medical necessity of a procedure or service as a part of the prior-authorization process. Here again, the proposals seem to raise more questions than they answer, and that has put COPA on alert.

It is not clear, for instance, what providers would be subject to the proposed medical record “clinical notes” requirement documenting medical necessity. Nor is it apparent to what extent this record-keeping requirement would apply to O&P practitioners.

Most troubling, perhaps, is the lack of specificity as to the nature of the actual record-keeping. What specific documentation of medical necessity shall accompany a prior-authorization request? There is no clarity here.

Record keeping is a touchy issue: Many providers already are troubled by the RAC audit situation, in which record keeping is at once necessary and, at the same time, seemingly arbitrary. No one wants to see that situation repeated on an even broader scale, says Docherty. “When they are adding new provisions and requirements on medical O&P providers,

telling them they are subject to clinical notes requirements, we need to know what those clinical note requirements are going to be.”

COPA laid out the issues in its written comments to the Medi-Cal hearing. “COPA needs to specifically articulate and advise our members on how best to meet these recordkeeping requirements. In general, the prior-authorization process can be fickle. We hope to minimize interruptions in providing O&P appliances and services to Medi-Cal beneficiaries by being abundantly clear on what specific documentation is necessary to expedite the prior-authorization process articulated in this proposed rulemaking.”

On the one hand, O&P is calling for clarity on the matter of required documentation. At the same time, this issue of record keeping overlaps a wider ongoing concern in the O&P community. Even as Medicare entities are calling for greater emphasis on note-taking, it remains unclear whether an O&P practitioner’s notes can even be included as part of the medical record.

As long as the issue of record keeping is on the table, some see this as an opportunity to finally make it clear that an O&P provider’s notes should and must be integrated into a patient’s medical documentation. “We just want to make sure that orthotists’ and prosthetists’ notes are recognized as a substantive part of the medical record,” Dale says.

COVER STORY

Prior Authorization

This matter of medical documentation makes up just one aspect of the broader prior-authorization landscape under consideration in California.

As part of its ongoing deliberations, Medi-Cal is considering a range of factors that, if unmet, would lead to a rejection of prior-authorization requests. While some of these may or may not pass the basic tests of being reasonable and practical, nearly all share a common failing: They are incomplete and ill-defined, generally insufficient in their language and clarity of intent.

Dig deeper into the matter of medical necessity, for example. It is reasonable, one might say, for a payor to ask for documentation of medical necessity before approving an appliance or service. What’s missing here are virtually all the details that would make this a realistic requirement.

Who will determine whether or not the device or service is essential to performing activities of daily living or instrumental activities of daily living?

It is not clear.

Who will determine whether or not the device or service is consistent with the patient’s previous abilities and limitations as they relate to activities of daily living, prior to the onset of disability or injury, or as appropriate to the patient’s chronological and developmental age? Again: This is not made specific in the proposed rules.

What qualifications would this presumed individual be required to have in order to make these determinations? How would these determinations be made and what tests would guide these determinations? Needless to say, this information is nowhere to be found in the rules.

One crucial concern in the realm of prior authorization involves the determination of active daily living and previous ability limitations. These can be “highly subjective,” COPA notes. Yet making the call correctly is a vital element in the patient’s overall

care. If Medi-Cal takes on this duty, it could incur significant costs for testing and evaluation. None of this is a recipe for success.

“COPA is concerned that subjective determinations on active daily living would not only delay the priorauthorization process and delay O&P care for Medi-Cal beneficiaries but also negatively impact the reimbursement timeline for providers that are already struggled with a challenging Medi-Cal reimbursement rate for these O&P appliances and services,” the organization writes.

The litany of uncertainty goes on. How will the O&P practitioner know whether a device or service is included in the hospital contract?

How and where is the “acute inpatient hospital stay” defined? Who will determine whether it is better to repair or replace a device, and how will that decision be made?

All these are crucial to O&P’s ability to provide timely and appropriate care. If changes are to be made to existing law and regulations, each aspect of that change need to be spelled out in exacting detail.

Medi-Cal is expected to continue its deliberations on these issues into the spring. In the meantime, COPA officials say they are tentatively optimistic that their extensive input on the relevant proposals will be given serious weight. “We have a decent working relationship with Medi-Cal, they have been willing to sit down with us and talk and answer questions,” Docherty said. “They have been decent partners, and we hope that will continue.”

Adam Stone is a contributing writer to O&P Almanac. Reach him at adam. stone@newsroom42.com.

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27

Primed for

Partnership

Patients reap the benefits when O&P professionals team up with the VA to care for the military population

By ANTHONY LAZZARINO, DPM

U

NTIL RECENTLY, THE DEPARTMENT of Veterans

Affairs (VA) lacked a standardized federal testing threshold based on the mechanical, functional, and safety-related properties of available therapeutic footwear. The VA has been paying hundreds of millions of dollars for therapeutic footwear of undefined quality. The absence of specific guidelines and ambiguous requirements has undoubtedly inflated the cost and effectiveness of therapeutic footwear products, and this shortcoming extends to other payors as well— including the Department of Defense Military Health System and CMS. The VA Northern California Health Care System (NCHCS) Podiatry Service addressed the problem of nonstandardized therapeutic footwear products head-on.

As a major provider of therapeutic footwear, VA NCHCS carries a

28

DECEMBER 2014 | O&P ALMANAC

responsibility to define footwear quality. Therapeutic footwear must meet defined performance and cost requirements. The defined standards for therapeutic footwear are not radical or designed to give unfair advantage to any party. These standards are organized utilizing accepted footwear industry methodology.

VA NCHS standardization efforts don’t stop here. Similar standardization programs are being undertaken for in-shoe orthotic devices, and progress also is being made to define similar minimum product quality standards for all lower-extremity orthotic and prosthetic devices. This standards development effort is not taking place in a vacuum. Rather, it’s a broad-based project drawing on the work already done in this area by organizations such as the American National Standard Institute (ANSI), ASTM International (formerly known as the American Society for Testing

and Materials), DIN (the German Institute for Standardization), SATRA, Shoe and Allied Trade Association (United Kingdom, European Union, and People’s Republic of China), and the International Organization for Standardization.

While performance and quality evaluations are made for the composite structure of therapeutic footwear, they also extend to footwear components including the whole shoe, leather, rubber outsoles, PU outsoles, EVA outsoles, insoles, PU, PVC, polymer composites, lining, and upper fabric and shanking.

The average cost of an ulceration from a poorly fitted therapeutic device, whether at the onset of use or following many months of usage, is $60,000 per incident. The average cost for a patient to sit in a VA clinic, for each visit, starts at approximately $1,600.

Then add the cost of whatever devices are provided during that visit.

Returning to quality-of-life issues, the average life expectancy of a diabetic at risk for limb loss following a first ulceration is approximately five years. At VA NCHCS, we have spent over $1 million in a limb salvage and gait restoration effort, for one patient.

Opportunities for O&P Professionals

It is inaccurate to say that all prescribing physicians have the knowledge that a professional such as a pedorthist, orthotist, or prosthetist has in dealing with these patients, involving the delivery of effective therapeutic aids.

The insight, craftsmanship, and product delivery of certified O&P practitioners is invaluable to the VA. Many individuals in the AOPA membership would like to expand their practice and income potential, and are examining the present economics to the health-care market. The Affordable Care Act and the overall health-care economy remain in serious flux. But perhaps O&P professionals should consider the VA when seeking new opportunities.

The VA is economically stable and is the largest integrated health-care

system, with more than 1,700 facilities.

The veteran population of 22.3 million in 2012 is growing. The number of enrollees—8.76 million—also is growing, and the system offers more comprehensive orthotic, prosthetic, and footwear benefits than Medicare or private health-care providers.

The VA can be important to an O&P practice because its impact is real and enormous. The VA’s Prosthetic and Sensory Aids Service (PSAS) is the most comprehensive provider of durable medical equipment and prosthetic devices in the world. Veterans requiring orthotic and prosthetic products from the VA exceeded 1.9 million in FY 2008. As demand increased, costs accelerated from $532 million in 2000 to $1.6 billion in 2008. In FY 2012, the VA system surpassed the level of goods and services provided in previous years, spending more than $2 billion to provide PSAS services to more than 2.7 million veterans.

Nearly half of all veterans currently seen in VA facilities for health care receive prosthetic and sensory aids services, and nearly one third obtain rehabilitative health-care services. Our nation has been engaged in military conflicts in Vietnam, the Persian Gulf, Africa, Bosnia, Kosovo, Iraq, and Afghanistan. Medical and tactical advancements have resulted in a significant increase in the survivability of combat-related injuries in Iraq and Afghanistan. A major goal of the VA is to maximize a veteran’s independence and maintain an optimal level of function—to enable that veteran to integrate successfully into his or her community.

This goal is in exact alignment with the goal of the O&P profession.

The VA provides the full spectrum of world-class prosthetic, orthotic, and rehabilitation services for veterans.

O&P services are key in providing rehabilitative services for this population. Regardless, if such services are needed as a result of ordinary healthrelated changes or having originated from more complex and multiple injuries (i.e., polytrauma), O&P professionals are integral to the full restoration of our veteran patients.

Full-Service Health Care

The VA system is officially committed to providing veterans the best possible care and service available for their lifetime. As a result of VA initiatives, every veteran in need of orthotic and prosthetic service will receive the full measure of services and products available. In a recent initiative, which impacts the full scope of practice represented in AOPA membership, any veteran at risk for limb loss will receive prescription therapeutic footwear.

All practicing pedorthists, orthotists, and prosthetists have had an increasingly important role in the management of diabetes and neuromuscular/vascular disorder. Nearly one in four veterans has diabetes.

The Centers for Disease Control and Prevention estimates that nearly 26 million people, or about 8 percent of the U.S. population, have diabetes.

That includes about 11 million persons 65 and older, about 27 percent of seniors, and approximately 10 percent of all veterans receiving benefits.

At some point, most of this large pool of patients will utilize VA benefits, and will subsequently require orthotic, prosthetic, and/or pedorthic services.

A team effort between the VA and O&P professionals will serve these veterans well.

EDITOR’S NOTE: The complete VA NCHCS Therapeutic Footwear Standards can be downloaded at http://bit.ly/1vcjy65.

Anthony Lazzarino, DPM, is chief of podiatry services at the VA Northern California Health Care System (NCHCS). Lazzarino prepared an expanded version of this article as a presentation during the 2014 AOPA National Assembly’s pedorthic track program on therapeutic footwear. He was unable to attend the Las Vegas event, but agreed to share this condensed version of his remarks with readers of the O&P Almanac. Reach him at dranthonylazzarino@gmail.com.

O&P ALMANAC | DECEMBER 2014

29

MEMBER SPOTLIGHT

Coyote Design

By DEBORAH CONN

Complete Care and Fabrication With both a patient-care and a manufacturing business, the owners of Coyote Design keep their finger on the pulse of O&P

F

IFTEEN YEARS AGO, DALE

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DECEMBER 2014 | O&P ALMANAC

Dale Perkins, CPO, on right

COMPANY: Coyote Design LOCATION: Boise, Idaho OWNERS: Dale Perkins, CPO, and Matt Perkins HISTORY: 15 years

addition, the company recently introduced a different composite material as an alternative to carbon fiber. Coyote Composite is made from a filament of melted basalt that is braided for use in O&P components. It is available as a weave, rope, and fabric. “It’s a little safer, less irritating fabrication method than laminating carbon sockets,” says Matt.

Coyote Design occupies a 6,000 square-foot building in Boise. “When we purchased it, we intended to lease out a third of the space,” says Matt. “I’m glad we didn’t, and it’s definitely too small for us now.” The company has purchased a larger building and will be moving in the spring.

One of the operations occupying space in the building is a centralized lab for the two Rehab Systems offices. According to Matt, it is serving as a pilot program for a central fabrication facility that will serve other patient-care practices. “This would be on a limited basis,” he

says. “We would focus on our own socket and AFO designs.”

Having both a patient-care and a manufacturing business allows the company to see firsthand what is needed in the field.

“We can develop products that our patient base needs, and we find niches in the marketplace we can fill,” says Matt. “And as amputees ourselves, we’re trying to make products that we would be willing to use.”

Coyote promotes its products primarily through educating orthotists and prosthetists in the use of its products. The company also participates at national trade shows such as AOPA’s National Assembly and leverages print advertising. “One of our courses focuses on a transtibial socket design and method we developed. We’re in the process of moving that training online, and expect that by next year, most of our courses will be available through our website,” says Matt.

Coyote Design currently has 11 employees, including Chief Financial Officer Peggy Perkins, Dale’s wife. Matt expects the business will continue to grow, but wants it to do so in a sensible way. “We’ve never wanted to grow just for growth’s sake,” he says. “We prefer staying lean and smart rather than getting too big, too fast. I expect we’ll try to fit in our new building for some time to come.”

Deborah Conn is a contributing writer to O&P Almanac. Reach her at deborahconn@verizon.net.

PHOTO: Coyote Design

Perkins, CPO, and his son Matt founded Coyote Design, which manufactures orthotic and prosthetic devices and components.

Dale Perkins began his career as a clinician and has a deeply personal interest in the field: He was born with fibular hemimelia and had his left leg amputated above the knee 20 years ago.

In 1993, Perkins established his patient-care facility, Rehab Systems Orthotic and Prosthetic Technologies, in Twin Falls, Idaho, and Matt started working for him as a technician. Rehab Systems has two offices now, one in Twin Falls and one in Boise.

Matt also is a transfemoral amputee, as the result of a different congenital issue, proximal femoral focal deficiency. He spent most of his 20s as a ski racer with the U.S. Disabled Ski Team, competing in the Nagano Paralympics in 1998 while working for his father. Matt retired as a ski racer in 2002, but he continues to compete in triathlons and has won the International Triathlon Union World Championships five years in a row.

Dale and Matt decided to launch an O&P manufacturing facility when they kept encountering difficulties in the fitting and fabricating process. Working with a patient who was a machinist, the two developed a prosthetic prototype and began to market it.

Today, Coyote focuses primarily on suspension systems, designing a range of locking mechanisms, lab equipment, and materials. In

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The study was commissioned by the Amputee Coalition and conducted by Dr. Allen Dobson, health economist and former director of the Office of Research at CMS. The study used Medicare data to compare patients with similar conditions who received prosthetics with patients who needed but did not receive prosthetics, over an 18 month period.

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EXHIBIT 4.9 Lower Extremity Prostheses Cumulative Medicare Episode Payment by Cohort (18 Month Episodes from 2008-2010)

Lower Limb Prosthetics

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80000

40000

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3

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5

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9 10 11 12 13 14 15 16 17 18

Months from Index (Receipt of O&P)

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MEMBER SPOTLIGHT

Tillges Certified Orthotic Prosthetic Inc.

By DEBORAH CONN

High-Tech, High-Touch Patient care, advanced technology, and quality fabrication are all priorities at Tillges Certified Orthotic Prosthetic

R

OBERT TILLGES HAS BEEN

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DECEMBER 2014 | O&P ALMANAC

Michael Tillges, CPO, fits a bilateral EMS sockets on patient Troy.

FACILITY: Tillges Certified Orthotic Prosthetic Inc. LOCATION: Maplewood, Woodbury, and Minneapolis, Minnesota, 9 clinics in western Wisconsin and Twin Cities metropolitan area OWNER: Robert Tillges, CPO, FAAOP HISTORY: 22 years

TCOP fabricates all of its own devices, with a main laboratory in Maplewood and a smaller fabrication facility in Minneapolis. The company also is a certified provider of the M.A.S. socket, and has created a hybrid prosthesis by combining that socket with the High Fidelity Interface produced by California-based Biodesigns Inc. In 2012, Tillges launched a subsidiary of the company called Tillges Technologies, which focuses on advanced technology and provides central fabrication services for O&P businesses throughout the country. Tillges Technologies developed a wireless pressure sensor device, PressureGuardian, to help practitioners manage diabetic ulcers and improve the fit of orthotic and prosthetic devices.

The device measures pressure loads and force and transmits the information to clinicians and patients via an app for Apple iOS smart phones and tablets.

Two of Tillges’s sons, Michael and Steve, are both certified

prosthetists and orthotists at TCOP. Michael, who also has a bachelor’s degree in mechanical engineering, began as a technician and joined full time as a practitioner in 2004. Steve holds a business degree and began working at TCOP as a practitioner in 2005. A third son, David, is a technician currently pursuing his master’s degree in orthotics and prosthetics.

“We exist to serve patients who come in here on a daily basis,” says Tillges. “I think of our focus as a pyramid. At the top are our customers. Next in line are our referral sources and then insurance payers. As far as I’m concerned, my CEOs and CFOs are at the bottom of the pyramid.

Without the customers at the top to take care of, we wouldn’t exist.”

The quality of TCOP’s fabrication is a major strength, says Tillges. “We do everything in house, so we have total control over the quality and turnaround time for our devices.”

He relies on word of mouth and a strong reputation to market his business. TCOP conducts many in-service educational sessions at doctors’ offices, hospitals, and physical therapy sites, with some qualifying for continuing education credits.

Tillges also plans for more expansion in the future. “We will keep going,” he says. “In fact, I just talked to a new potential hire this morning.”

Deborah Conn is a contributing writer to O&P Almanac. Reach her at deborahconn@verizon.net.

PHOTO: Tillges Certified Orthotic Prosthetic Inc.

in the O&P industry for 38 years. He began his career as a technician, working for Dan Rowe & Associates in St. Paul, Minnesota. After becoming a certified orthotist and prosthetist, he ran a small facility for Northwestern Artificial Limb and Brace. In 1992, he opened Tillges Certified Orthotic Prosthetic Inc. (TCOP).

“We were in an 1,800-squarefoot space,” he recalls. “I started by myself with a secretary.

I would see patients all day and fabricate devices at night.

It was a lot of hours.”

Tillges’s business grew, and in 1995, he moved into a 4,200-square-foot space.

Today, TCOP occupies a 13,000-square-foot facility in Maplewood, Minnesota, with branches in Woodbury and Minneapolis. In addition, TCOP provides O&P services through nine clinics in western Wisconsin and throughout the Minneapolis-St. Paul metropolitan area.

The Maplewood facility has seven fitting rooms, two casting rooms, a large gym area with two sets of 25-foot parallel bars, a full lab, and space for the front office and upstairs billing department.

TCOP’s patients run the gamut from pediatric to geriatric, and the practice provides “full service, head to toe,” Tillges says.

Clinicians see military patients as well as civilians, and quite a few highly active patients who require more advanced devices.

The facility also offers a wide range of compression garments and postmastectomy products.

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AOPA NEWS

THE AOPA BULLETIN

Changing of the Guard A new team is driving the AOPA agenda and protecting the future of O&P

2015 AOPA Officers

In our quest to deliver maximum return on investment to you the reader and AOPA member, each issue of O&P Almanac will summarize recent actions AOPA has undertaken in making a difference in solving problems or meeting challenges faced by the O&P community and deliver a greater ROI on the AOPA investment for all of O&P.

34

A

NOTICEABLE AIR OF RELIEF and more positive

energy during the 97th AOPA National Assembly were noted by many of the attendees of the September event at the Mandalay Bay Resort and Casino in Las Vegas. It was akin to a gathering of athletes who had been through a challenge, proud to reach another milestone relatively intact. This “We’re here to stay” attitude was especially visible at the annual business meeting on Saturday, September 6, when AOPA welcomed new officers, learned the facts on AOPA’s

Charles Dankmeyer, CPO, President

James Campbell, PhD, CO, FAAOP, President-Elect

DECEMBER 2014 | O&P ALMANAC

fiscal status, and heard three no-nonsense, upbeat messages from key members of the AOPA leadership team and staff.

AOPA marched into the 21st century with electronic voting during the business meeting.

The 2012 annual meeting bylaws amendment permitting electronic voting confirmed its value in time and energy saved. With members voting electronically for the slate of officers and new directors presented by the Nominating Committee, there was no need for hand counting of ballots, and no last-minute rounding

up of members to ensure a quorum. What’s more, those board members who previously volunteered for the complicated early-morning vote managing process were relieved of an always hectic last-minute scramble.

Instead, the electronic voting process proved a success. The 2014 Nominating Committee, chaired by Tom Kirk, PhD, and consisting of past presidents Jim Kaiser, CP, and Tom DiBello, CO, FAAOP, submitted their nominees to the membership electronically for their vote in early August.

With several reminders from the AOPA office, the number of members voting exceeded the required quorum just days before the big event. During the meeting, AOPA President Anita Liberman-Lampear, MA, simply introduced the new officers and board members.

Charles H. Dankmeyer Jr., CPO, was introduced as AOPA’s new president, to take office effective

Anita Liberman-Lampear, Michael Oros, CPO, Vice President MA, Immediate Past President

Jeff Collins, CPA, Treasurer

Maynard Carkhuff

Eileen Levis

Dave McGill At-Large Director

Scott Schneider

Don Shurr, CPO, PT

Pam Lupo, CO

Jeffrey Lutz, CPO

Dec. 1, 2014. Jim Campbell, PhD, CO, moved into the president-elect position.

Michael Oros, CPO, is the newly elected vice president, and Jeff Collins, CPA, fills the treasurer role. These four officers, along with Liberman-Lampear (now immediate past president), constitute the 2014-2015 Executive Committee, which is empowered to act in the board’s stead when the board is not in session. The Executive Committee meets every two weeks via conference call to work with AOPA staff in ensuring board policy is being effectively implemented and in shaping responses to the pressing issues in regulation and legislation threatening the O&P field.

Also elected to a three-year term as directors were Pam Lupo, CO, as the 6-30 patient-care facility representative on the board; Jeffrey Lutz, CPO, representing the 31+ patient-care facilities members; and Chris Nolan as

Chris Nolan, Supplier Director

SPECIAL THANKS • RETIRING

CONTINUING

AOPA NEWS

2015

NEW

2015 AOPA Board Members

THE AOPA BULLETIN

Tom Kirk, PhD

Alfred E. Kritter Jr., CPO, FAAOP

Jim Weber, MBA

Ronald Manganiello

the supplier director. All are eligible to serve one additional three-year term.

Retiring from board service were Al Kritter, CPO, FAAOP, who represented 31+ patient-care facilities, and Ron Manganiello, at-large director. Tom Kirk, PhD, completed his service as immediate past president, and Jim Weber, MBA, completed his term as treasurer when his five-year stewardship of AOPA finances ended Nov. 30, 2014.

AOPA’s finances under Weber’s watchful eye withstood some of the most challenging demands over the past few years but still managed to keep producing a healthy balance sheet.

Not once did the association’s fiscal year end in the red, and AOPA has sustained or increased surplus to allow us to tackle the big challenges ahead.

When Liberman-Lampear presented Weber with a plaque for his service as treasurer, she said, “If there is anyone

in the world with whom I would entrust with my checkbook, it would be you.”

This careful financial management provided AOPA the wherewithal to undertake much-needed research in the long-neglected areas of comparative and cost effectiveness studies, which are paying huge dividends through the Mobility Saves Lives and Money project and the data-driven policy positions that carry weight with Congress and the regulators. The fight on Recovery Audit Contractor audits and other missteps

by CMS were not delayed because of lack of funds, and AOPA was able to file a lawsuit against CMS in a timely manner because the funds were in place. Despite being dismissed, there appear to be benefits flowing from the litigation in the form of recently proposed CMS policy changes following the letter of the law provided in the Administrative Procedure Act (APA) O&P ALMANAC | DECEMBER 2014

35

AOPA NEWS

THE AOPA BULLETIN

Charles Dankmeyer, CPO

requiring notice to stakeholders and an adequate comment period before finalizing. That was the key complaint in AOPA’s lawsuit: that CMS violated the law (APA), cutting corners when implementing the policy change articulated in the “Dear Physician Letter.”

As incoming president, Dankmeyer lamented the failure of the O&P community to achieve three basic things: “securing our service turf, qualified provider recognition, and payment for services.” He asked the audience, “Do you want those three fundamental things? Working as one, we can focus and accomplish these goals. I need your help.”

Anita Liberman-Lampear, MA 36

DECEMBER 2014 | O&P ALMANAC

As outgoing president, LibermanLampear recalled her comments when she initially took office when she said, “I made a plea one year ago, which I am going to repeat. We must look outward.

Like Mobility Saves, we must find tools to make sure that the outside world knows what we accomplish for the good of our fellow humans. That plea also included making it your personal agenda to broaden the support this profession gives to AOPA. I know firsthand the incredible daily challenges that drain our energy and our resources. Those must be replenished, and only you can make that happen.

Please do your very best to encourage any colleagues you know who are sitting on the sidelines to get into the game.”

Thomas F. Fise, JD

AOPA Executive Director Tom Fise recounted in more detail the numerous issues AOPA was called upon to address this year, saying, “So while it has been a year of some successes and some disappointments, we will keep pressing with all of the resources we can muster on your behalf and using every possible tool to make sure that we have done all we can to protect your patients and your business. One major success of the past continues to keep on giving: The exemption we secured in 2012 from the Medical Device Excise Tax spares O&P patient-care facilities and manufacturers about $100 million in taxes every year, [money that is] being paid by others in the medical field selling medical devices. Thank you for

Karl Fillauer, CPO, with Liberman-Lampear

your support this past year as we ask you to please continue that support.”

Two noteworthy recognitions occurred at the business meeting, reminding everyone of the generous and selfless nature of people in the field. Karl Fillauer, CPO, chief executive officer of the Fillauer group of companies, received the Lifetime Achievement Award, not only for his personal contributions to O&P but also for the stature he has helped his group of companies achieve in the field.

Jim Kaiser, CPO, a past president of AOPA, was awarded the Ralph “Ronney” Snell Legislative Advocacy Award for his numerous successes at both the national and state levels. His tireless efforts in pursuing policy favorable to O&P professionals and their patients were acknowledged—most notably, the amputee fairness legislation in Illinois. Though Kaiser was unable to attend the meeting, Michael Oros, CPO, accepted the award on Kaiser’s behalf and shared remarks Kaiser authored to express his appreciation for the award and give credit to his associates at Scheck and Siress and the organization, Families of Amputees in Motion.

Join us for next year’s annual meeting during the 98th National Assembly in a big night-and-day venue change from Las Vegas as AOPA goes to the River Walk area in downtown San Antonio, Texas, Oct. 7-10, 2015.

AOPA NEWS

Call for Papers: Become a Presenter at the 2015 AOPA National Assembly Share Your Expertise• Advance Your Career • Improve Patient Care Henry B. Gonzalez Convention Center, San Antonio, TX

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tations for the 98th Annual AOPA National Assembly.

Share your expertise and advance your career by being part of the country’s oldest and largest meeting for the orthotic, prosthetic, and pedorthic profession.

Your submissions, based on sound research and strong empirical data, will set the stage for a broad curriculum of highly valued clinical and scientific offerings at the 2015 AOPA National Assembly. All free paper abstracts for the 2015 AOPA National Assembly must be submitted electronically. Abstracts submitted by email or fax will not be considered. All abstracts will be considered for both podium and poster presentations.

The review committee will grade each submission via a blind review process, based on the criteria below, and reach a decision regarding acceptance of abstracts.

• Relevance, level of interest in topic • Quality of scientific content • Quality of clinical content All papers should be submitted at www.aopanet.org/ education/2015-assembly/present/. AOPA is accepting submissions for the following topics: • Clinical Free Papers: The top-scoring papers will compete for the prestigious Thranhardt Award.

• Technician Program • Business Education Program: The top papers will be considered for the prestigious Sam E. Hamontree, CP (E), Business Education Award.

• Symposia • Student Poster Submissions • Technical Fabrication Contest Submissions Contact AOPA Headquarters at 571/431-0876 or TMoran@AOPAnet.org with questions about the submission process or the National Assembly.

Mastering Medicare Webinar:

New Codes and Changes for 2015

Participate in the seminar Dec. 10, 2014

H

IPAA REQUIRES ALL PAYERS to use codes from the Healthcare Common Procedure Coding System (HCPCS). The end of the year marks the beginning of new codes and modifier changes that will be effective Jan. 1, 2015.

Do you have a plan in place? The ability to make sure your practice is sound may prevent unnecessary audits down the road. As we welcome a new year, join AOPA for a webinar that will focus on new codes and medical policy changes for 2015 and why these are an important part of your business operation.

An AOPA expert will address the following topics: • HCPCS codes effective Jan. 1, 2015 • Verbiage changes to existing codes and how they may affect your business • Which codes will no longer be used as of Jan. 1, 2015 • Other changes to the HCPCS system • AOPA’s interpretation of why the changes took place • Other pertinent policy/legislative changes for 2015

The cost of participating is $99 for AOPA members ($199 for nonmembers), and any number of employees may partake on a given line. Attendees earn 1.5 continuing education credits by returning the provided quiz within 30 days and scoring at least 80 percent.

Register online at bit.ly/2015codes. Contact Devon Bernard at dbernard@AOPAnet.org or 571/431-0854 with content questions. Contact Betty Leppin at bleppin@ AOPAnet.org or 571/431-0876 with registration questions.

O&P ALMANAC | DECEMBER 2014

37

AOPA NEWS

AOPA Attends OMHA’s 2nd Medicare Appellant Forum

T

HE OFFICE OF MEDICARE Hearings and Appeals’ (OMHA)’s second Appellant Forum on October 29 attracted a much smaller onsite participation level than its February forum, and any hoped-for relief from the long administrative law judge (ALJ) hearing delays did not emerge.

Chief Administrative Law Judge Nancy Griswold confirmed the ALJ office is receiving approximately 14,000 appeals per week compared to 1,250 per week in 2011, prior to the “Dear Physician” letter that triggered the dramatic increase in recovery audit contractor audits. She announced the time Judge Nancy Griswold from the request for a hearing until an ALJ decision is rendered is currently 414.8 days and is expected to increase.

An 18.6 percent budget increase for 2014 with additional increases expected in 2015 should provide some relief. In addition, a new field office in Kansas City with seven new ALJ teams, with 10 more expected in 2015, will further relieve the backlog. CMS now has a patient relations coordinator to help improve relations between providers and CMS stakeholders, and she will assist in educating contractors.

In attendance from AOPA at the October 29 forum were Joe McTernan, AOPA’s director of coding and reimbursement services, education, and programming, and Lauren Anderson, manager of communications, policy, and strategic initiatives.

Receipt data corrected from original presentation

OMHA Workload – Received and Decided

AOPA’s 2015 Mastering Medicare Webinars Announced

M

ARK YOUR CALENDAR NOW for the 2015 AOPA Webi-

nars. These one-hour sessions come to you in the comfort of your office on the second Wednesday of each month at 1 p.m. EST. This series provides an outstanding opportunity for you and your staff to stay up-to-date with the latest hot topics in O&P, as well as gain clarification and ask questions on topics that you may not understand as fully as you would like to. You may access the webinars by phone or computer.

Buy the Series and Get Two FREE! • January 14: Fill In the Blanks: VA Contracting and the New Template • February 11: Find Success: Tips, Strategies, and Understanding the Appeals Process • March 11: Who Gets the Bill: A Complete Look at Medicare Inpatient Billing • April 8: Lower-Limb Prostheses Policy: Learn the Policy Inside and Out • May 13: The New Player in Town: Understand How the RAC Contract Works • June 10: Stay Out of Trouble: Building a Medicare-Approved Compliance Plan • July 8: Who’s on First? Medicare as a Secondary Payer • August 12: Off-the-Shelf vs. Custom Fit: The True Story • September 9: Prior Authorization, How Does It Work?

• October 14: Understanding the LSO/TLSO Policy • November 11: How To Make a Good Impression: Marketing Yourself to Your Referrals • December 9: Bringing in the New Year: New Codes and Changes for 2016

450,000

400,000

395,000

384,151

350,000

Appeals

300,000

250,000

200,000

150,000 117,068

100,000

79,372

34,079 30,137

28,641 31,315

34,167 35,831

FY07

FY08

FY09

39,849 44,361

53,868

59,600

87,266

61,528

0 FY10

Decided Appeals

FY11 Received Appeals

FY12

FY13

FY14 YTD* Receipts through June 2014

*The FY14 recei pts a re ba s ed on es ti ma ted recei pts through June 2014.

Recei ved a ppea l s repres ents ca s es wi th Reques t for Hea ri ng Da te i n l i s ted yea r.

Deci ded a ppea l s repres ents ca s es deci ded i n l i s ted fi s ca l yea r no ma tter wha t yea r ca s e wa s recei ved.

Excl udes Rema nds , Reopened a nd Combi ned Appea l s .

Recei pts ma y be i ncompl ete due to da ta entry ba ckl og.

FY14 Da ta a s of September 30, 2014

Run Da te: November 13, 2014

Office of Medicare Hearings and Appeals (OMHA) – Medicare Appellant Forum – October 29, 2014 – Washington, D.C.

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DECEMBER 2014 | O&P ALMANAC

9

PHOTOS: www.hhs.gov

50,000

Visit the AOPA website, buy the series, and get two free. Members pay just $990 and nonmembers pay $1,990. If you purchase all of the conferences, all conferences from months prior to your purchase of the set will be sent to you as CDs. Seminars are priced at just $99 per line for members ($199 for nonmembers).

Questions? Contact Betty Leppin at bleppin@AOPAnet.org or 571/431-0876.

AOPA NEWS

O&P Alliance Meets With CMS Chronic Care Team

T

PHOTO: www.tammyduckworth.com

HE O&P ALLIANCE HELD a meeting with CMS Chronic Care Director Laurence Wilson, who manages the off-the-shelf (OTS) and competitive bidding program, as well as key members of his staff. AOPA Executive Director Tom Fise, Steve Fletcher of ABC, and Peter Thomas were in attendance on behalf of the O&P Alliance.

CMS issued two proposed rules in 2014, affecting both prosthetics and orthotics. On July 11, CMS released a proposed rule that addressed OTS orthoses and the definition of minimal self-adjustment. The proposed rule would add physicians, treating practitioners, physical therapists, and occupational therapists as “individuals with specialized training” to the current definition that includes certified orthotists as qualified individuals to provide custom fitting of orthoses. The proposed rule also states that orthotic assistants and fitters are not considered to have specialized training for the purposes of providing custom fitting of orthoses and therefore any devices they fit or adjust will be considered OTS. The issue of OTS orthotics was one of the first issues taken up at the meeting. The Alliance discussed the recent letter from Sens. Chuck Grassley (R-Iowa) and Tom Harkin (D-Iowa) to CMS Administrator Marilyn Tavenner on the expansive definition of OTS orthotics adopted by CMS. They made the case that CMS essentially wrote the word “self” out of the statutory term “minimal self-adjustment.” The Alliance also discussed AOPA’s data from the Dobson DaVanzo report on the number of patients who receive custom orthotics after receiving OTS orthotics, undercutting CMS’s arguments about cost savings. The Alliance also spoke about certified orthotic fitters and how the proposed rule is inconsistent with how CMS has treated fitters to date. Fortunately, the final rule published on October 31 omitted any changes that would have expanded the term “minimal self-adjustment” and did not specify which individuals could provide custom-fit orthoses.

On May 28, CMS issued a proposed rule that would require 89 lower-limb prosthetic codes to be subject to prior authorization, without eliminating RAC audits or providing a guarantee of payment. The Alliance discussed how a prior authorization demonstration on wheelchairs does not mean that CMS can apply prior authorization to everything, especially clinical care like lower-limb prostheses. Some CMS staff did not seem to be aware that

prior authorization applied to prosthetics, so the meeting provided an excellent educational opportunity.

After discussing how prior authorization was not a good fit for O&P care, and how many practitioners supported prior authorization only when compared to extensive RAC audits as the alternative, the Alliance discussed recommendations for making the proposal palatable, which can be found in AOPA’s submitted comments, available on AOPA’s website.

The CMS staff in attendance were familiar with the comments submitted by AOPA, its members, and patients regarding the proposed rules, and were aware of the congressional letter on OTS orthotics. CMS made no indications regarding when and if the competitive bidding would be implemented for OTS orthotics, or when any proposed rules may be implemented.

Duckworth Urges Assistance for O&P Profession

C

ONTINUING HER WORK AS a strong advocate on

behalf of the O&P profession, Rep. Tammy Duckworth (D-Illinois), herself an amputee and war hero from the day when the helicopter she was piloting was shot down in Iraq, has taken another major step on behalf of O&P professionals and their patients.

Moving beyond her efforts in Congress, during a meeting in September in Chicago, Duckworth requested that Susan Axelrod, who was appointed during the summer by President Obama as a special White House liaison on disabilities, advocate for special relief for O&P companies from recovery audit contractor audits.

Duckworth, who was accompanied by Jim Kingsley of Scheck & Siress, presented a specific six-point request, prepared by AOPA, during the meeting.

O&P ALMANAC | DECEMBER 2014

39

AOPA NEWS

Earn CE Credits by Reading the O&P Almanac!

E! QU IZ M EARN

2

BUSINESS CE

CREDITS P. 18

Coding Questions Answered 24/7

AOPA members can take advantage of a “click-ofthe-mouse” solution available at LCodeSearch.com.

AOPA supplier members provide coding information about specific products. You can search for appropriate products three ways—by L code, by manufacturer, or by category. It’s the 21st century way to get quick answers to many of your coding questions.

Access the coding website today by visiting www.LCodeSearch.com. AOPA’s expert staff continues to be available for all coding and reimbursement questions.

Contact Devon Bernard at dbernard@AOPAnet.org or 571/431-0854 with content questions.

UPS Savings Program BECAUSE OF THE HIGHLY EDUCATIONAL content of the O&P Almanac’s Reimbursement Page and Compliance Corner columns, O&P Almanac readers can now earn two business continuing education (CE) credits each time you read the content and pass the accompanying quizzes. It’s easy, and it’s free.

Simply read the Reimbursement Page column (appearing in each issue) and Compliance Corner column (appearing quarterly), take the quizzes, and score a grade of at least 80 percent. AOPA will automatically transmit the information to the certifying boards on a quarterly basis.

Find the digital edition of O&P Almanac at: • http://www.aopanet.org/publications/digital-edition/ Access December’s quiz and previous monthly quizzes at: • bit.ly/OPalmanacQuiz Be sure to read the Reimbursement Page article in this issue and take the December 2014 quiz.

Take advantage of the opportunity to earn up to four CE credits today! Take the quiz by scanning the QR code or visit bit.ly/OPalmanacQuiz.

AOPA Members now save up to 30% on UPS Next Day Air® & International shipping! Sign up today at www.savewithups.com/aopa!

Take advantage of special savings on UPS shipping offered to you as an AOPA Member. Through our extensive network, UPS offers you access to solutions that help you meet the special shipping and handling needs, putting your products to market faster.

AOPA members enjoy discounts for all shipping needs and a host of shipping technologies. Members save: • Up to 30% off UPS Next Day Air® • Up to 30% off International Export/Import • Up to 23% off UPS 2nd Day Air® All this with the peace of mind that comes from using the carrier that delivers outstanding reliability, greater speed, more service, and innovative technology. UPS guarantees delivery of more packages around the world than anyone, and delivers more packages overnight on time in the US than any other carrier. Simple shipping!

Special savings! It’s that easy! www.savewithups.com/aopa

www.bocusa.org

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DECEMBER 2014 | O&P ALMANAC

WELCOME NEW MEMBERS

T

HE OFFICERS AND DIRECTORS of the American Orthotic & Prosthetic Association (AOPA) are pleased to present these applicants for membership. Each company will become an www.AOPAnet.org official member of AOPA if, within 30 days of publication, no objections are made regarding the company’s ability to meet the qualifications and requirements of membership.

At the end of each new facility listing is the name of the certified or state-licensed practitioner who qualifies that patient-care facility for membership according to AOPA’s bylaws. Affiliate members do not require a certified or state-licensed practitioner to be eligible for membership.

At the end of each new supplier member listing is the supplier level associated with that company. Supplier levels are based on annual gross sales volume:

Level 1: equal to or less than $1 million Level 2: $1 million to $1,999,999 Level 3: $2 million to $4,999,999 Level 4: more than $5 million.

Bremer Brace of Florida Inc. 3627 University Blvd. S., Ste. 425 Jacksonville, FL 32216 904/346-0086 Category: Affiliate Bremer Brace of Florida Inc., Jacksonville, FL

Fourroux Prosthetics Inc. 2867 Acton Road Vestavia, AL 35243 205/874-9683 Category: Affiliate Parent Company: Fourroux Prosthetics Inc., Huntsville, AL

Erdmann Prosthetics & Orthotics 151 N. Sunrise Avenue, Ste. 805 Roseville, CA 95661 946/642-3015 Category: Patient-Care Facility Michelle Durante

Is Your Facility Celebrating a Special Milestone in 2015?

The O&P Almanac would like to celebrate the important milestones of established AOPA members.

To share information about your anniversary or other special occasion to be published in a future issue of O&P Almanac, please email cumbrell@contentcommunicators.com.

MARKETPLACE

Feature your product or service in Marketplace.

Contact Bob Heiman at 856/673-4000 or email bob.rhmedia@comcast.net.

Visit bit.ly/aopa14media for advertising options.

New Genesee Metro Liner From College Park The new College Park Genesee liner provides the ideal benefits required of a gel liner in an affordable package.

Shaped for fit and flexibility with cushioning comfort and excellent limb-conforming properties, this durable liner accommodates a wide range of users. The unique fabric provides a superior fiber to gel bond, reduces pistoning, and eases donning. Shear forces are absorbed to prevent skin friction as the mineral oil provides continuous moisture over the entire lifespan of the liner.

• Mineral oil infused for continuous skin hydration • Retrofits with industry standard liners of like thickness and profile • Longer length for the perfect fit • Suitable for K1-K3 levels.

Fillauer K2 Foot From PEL The Fillauer K2 Foot is engineered from the ground up for the functional level 2 patient. Engineered with a unique flexible keel, the K2 Foot provides better control and stability. And when the patient is ready to go, so is the K2 Foot with a compliant forefoot that loads easily and provides support through toe off. Features and benefits: • Flexible impact reducing design • Unique flexible keel/multi-axis design • Roll-Over Shape (ROS) designed for a natural gait • Positive lock foot shell interface for stability For more information, call PEL at 800/321-1264 or visit www.pelsupply.com.

For more information, call 800/728-7950 or visit www.college-park.com/liners.

O&P ALMANAC | DECEMBER 2014

41

AOPA NEWS

CAREERS

Mid-Atlantic

Southeast

Certified Orthotist

CPO or CO

Clarksburg and Morgantown, West Virginia Are you interested in the whole scope of orthotics?

At Morgantown O&P Center, we do shoes to cranials in settings ranging from the university hospital to rehab centers with lots of people visiting our offices. Want to be exposed to great challenges? Look into our special North Central West Virginia location.

Send resume to: Mark Gorman, CPO Morgantown O&P Center 7000 Hampton Center, Ste. A Morgantown, WV 26505 Phone: 304/598-0528 Email: mgtnop@comcast.net Website: www.mgtnop.com

A unique opportunity to be a part of a rapidly expanding, multi-center department.

CERTIFIED ORTHOTIST / PROSTHETIST Department of Orthopaedic Surgery Functional Title: Academic Administrator

Chattanooga, Tennessee Fillauer Companies Inc. is seeking a CPO or CO to join its team as the director of orthotics at its headquarters in Chattanooga, Tennessee. In this role, the qualified candidate will manage the product development and clinical education for Fillauer’s orthotic product lines.

Requirements: • Education minimum: Bachelor’s degree in O&P. Engineering degree and/or a master’s degree in O&P a plus.

• ABC certification, preferred.

• Minimum of five years of recent patient-care experience with emphasis on orthotics.

• Licensed or ability to be licensed in the state of Tennessee.

• If not currently living in Chattanooga or the surrounding area, candidate must be willing to relocate.

• Engineering experience preferred. Proficient in CAD and SolidWorks a plus.

• Must work well in a team environment.

• Excellent communications skills, including oral and written, are necessary.

• Must have the ability to travel up to 30 percent or as needed.

Fillauer Companies Inc. offers a competitive benefits package, including 401K and medical, dental, and vision insurance. Please apply at:

Incumbent will work as full-time clinician in the Orthotic and Prosthetic Center in a large medical university, providing care for patients with a wide variety of medical diagnoses in both inpatient and outpatient care settings.

Candidate will be responsible for clinical evaluations, implementation of a wide assortment of orthotic/ prosthetic treatment modalities, and technical fabrication of orthotic / prosthetic devices. Candidate will also be responsible for assuming a supervisor role of two or more clinicians ensuring efficient clinical flow and quality of care. Applicant will be required to create and present informative educational presentations to allied health providers. Candidate will serve as resident instructor, which includes providing technical and clinical education to residents in a clear and concise manner. Medical benefits and pension plan are included.

Salary will be commensurate to applicant’s qualifications and experience.

Website: Fillauer.com/careers

REQUIRED QUALIFICATIONS: • ABC Certified Orthotist/Prosthetist; • Prior experience providing direct patient care in an orthotic and prosthetic facility; • Demonstrated skills, knowledge and abilities essential to successful performance of duties in a patient care setting; • Demonstrated excellent communication and team-building / interpersonal skills.

PREFERRED QUALIFICATIONS: Knowledge of disease processes and associated orthotic / prosthetic intervention; Familiarity with current treatment modalities, materials and fabrication techniques; Ability to work efficiently, and effectively.

Please apply online with CV at: http://apptrkr.com/538841 UCSF seeks candidates whose experience, teaching, research, or community service has prepared them to contribute to our commitment to diversity and excellence. UCSF is an Equal Opportunity/Affirmative Action Employer.

42

DECEMBER 2014 | O&P ALMANAC

SUBSCRIBE

A large number of O&P Almanac readers view the digital issue— If you’re missing out, apply for an eSubscription by subscribing at bit.ly/AlmanacEsubscribe, or visit issuu.com/americanoandp to view your trusted source of everything O&P.

CAREERS

Opportunities for O&P Professionals Job location key: - Northeast - Mid-Atlantic

O&P Almanac Careers Rates Color Ad Special 1/4 Page ad 1/2 Page ad

Member $482 $634

Nonmember $678 $830

Listing Word Count 50 or less 51-75 76-120 121+

Member Nonmember $140 $280 $190 $380 $260 $520 $2.25 per word $5 per word

- Southeast - North Central - Inter-Mountain - Pacific

Hire employees and promote services by placing your classified ad in the O&P Almanac. When placing a blind ad, the advertiser may request that responses be sent to an ad number, to be assigned by AOPA. Responses to O&P box numbers are forwarded free of charge.

Include your company logo with your listing free of charge.

Deadline: Advertisements and payments need to be received one month prior to publication date in order to be printed in the magazine. Ads can be posted and updated any time online on the O&P Job Board at jobs.AOPAnet.org. No orders or cancellations are taken by phone. Submit ads by email to landerson@AOPAnet. org or fax to 571/431-0899, along with VISA or MasterCard number, cardholder name, and expiration date. Mail typed advertisements and checks in U.S. currency (made out to AOPA) to P.O. Box 34711, Alexandria, VA 22334-0711. Note: AOPA reserves the right to edit Job listings for space and style considerations.

ONLINE: O&P Job Board Rates Visit the only online job board in the industry at jobs.AOPAnet.org.

Job Board

Member Nonmember $80 $140

For more opportunities, visit: http://jobs.aopanet.org.

Discover new ways to connect with O&P professionals.

Contact Bob Heiman at 856/673-4000 or email bob.rhmedia@comcast.net. Visit bit.ly/aopa14media for advertising options.

O&P ALMANAC | DECEMBER 2014

43

CALENDAR

2014

2015

December 4-6

R.I.C.: Pediatric Gait Analysis: Segmental Kinematic Approach to Orthotic Management. Chicago. Elaine Owen. 21.50 ABC Credit application. Contact Melissa Kolski at 312/238-7731 or visit www.ric.org/education.

December 6-7

ABC: Prosthetic Clinical Patient Management (CPM) Exam. Caruth Health Education Center, St. Petersburg College, FL. Contact 703/836-7114, email certification@abcop.org, or visit www.abcop.org/certification.

December 10

AOPA: New Codes and Changes for 2015. Register online at bit.ly/aopawebinars. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.

January 1

Application Deadline for Certification Exams.

Applications must be received by January 1 for individuals seeking to take the March 2015 ABC certification exams for orthotists, prosthetists, pedorthists, orthotic fitters, mastectomy fitters, therapeutic shoe fitters, orthotic and prosthetic assistants, and orthotic and prosthetic technicians. Contact 703/836-7114, email certification@abcop.org, or visit www.abcop.org/certification

January 9-11

O&P, Its Leadership, and Its Future. Palm Beach, FL. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.

Webinar Conference

December 12-13

ABC: Orthotic Clinical Patient Management (CPM) Exam. Caruth Health Education Center, St. Petersburg College, FL. Contact 703/836-7114, email certification@abcop.org, or visit www.abcop.org/certification.

Year-Round Testing BOC Examinations. BOC has year-round testing for all of its examinations. Candidates can apply and test when ready, receiving their results instantly for the multiple-choice and clinical-simulation exams.

Apply now at http://my.bocusa.org. For more information, visit www.bocusa.org or email cert@bocusa.org.

www.bocusa.org

Calendar Rates Let us share your upcoming event!

Telephone and fax numbers, email addresses, and websites are counted as single words. Refer to www.

AOPAnet.org for content deadlines.

44

DECEMBER 2014 | O&P ALMANAC

January 12-17

ABC: Written Simulation Certification Exams.

ABC certification exams will be administered for orthotists, prosthetists, pedorthists, orthotic fitters, mastectomy fitters, therapeutic shoe fitters, orthotic and prosthetic assistants, and orthotic and prosthetic technicians in 250 locations nationwide. The application deadline for these exams was November 1. Contact 703/836-7114, email certification@abcop.org, or visit www.abcop.org/certification.

Online Training

Cascade Dafo Inc. Cascade Dafo Institute. Now offering a series of six free ABC-approved online courses, designed for pediatric practitioners. Visit www.cascadedafo.com or call 800/848-7332.

CE For information on continuing education credits, contact the sponsor.

Questions? Email landerson@AOPAnet.org.

CREDITS

BONUS! Listings will be placed free of charge on the “Attend O&P Events� section of www.AOPAnet.org.

Words/Rate: Member Nonmember Color Ad Special: Member Nonmember 25 or less $40 $50 1/4 page Ad $482 $678 26-50 $50 $60 1/2 page Ad $634 $830 51+ $2.25/word $5.00/word

Send announcement and payment to: O&P Almanac, Calendar, P.O. Box 34711, Alexandria, VA 22334-0711, fax 571/431-0899, or email landerson@AOPAnet.org along with VISA or MasterCard number, the name on the card, and expiration date. Make checks payable in U.S. currency to AOPA. Note: AOPA reserves the right to edit Calendar listings for space and style considerations.

THE PREMIER MEETING FOR ORTHOTIC, PROSTHETIC, AND PEDORTHIC PROFESSIONALS.

Save the Date

OCTOBER 7-10, 2015 Mark your calendars for an ideal combination of top-notch education and entertainment at the 98th AOPA National Assembly in San Antonio, Texas. We look forward to seeing you in 2015!

For information about the show, scan the QR code with a code reader on your smartphone or visit www.AOPAnet.org.

CALENDAR January 14

Fill In the Blanks: VA Contracting Webinar Conference and the New Template. Register online at bit.ly/aopawebinars. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.

January 15-16

POMAC (Prosthetic and Orthotic Management Associates Corporation) Continuing Education Seminar. Shorebreak Hotel at Huntington Beach, CA. Contact John Shreter at 800/946-9170 x108 or email jshreter@pomac.com.

May 14-16

Western and Midwestern Orthotic & Prosthetic Association (WAMOPA).

Peppermill Hotel Resort, Reno, NV. Contact Sharon Gomez at 530/521-4541, or visit www.wamopa.com.

June 10

Stay Out of Trouble: Building a Medicare-Approved Compliance Plan.

Register online at bit.ly/aopawebinars. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.

Webinar Conference

July 8

February 9-10

AOPA: Mastering Medicare Essential Coding & Billing Techniques Seminar. Embassy Suites, Savannah, GA. Register online at bit.ly/2015billing. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.

February 11

Find Success: Tips, Strategies, and Understanding the Appeals Process.

Register online at bit.ly/aopawebinars. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.

Webinar Conference

March 11

Who Gets the Bill: A Complete Look at Medicare Inpatient Billing. Register online at bit.ly/aopawebinars. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.

Webinar Conference

April 8

Lower-Limb Prostheses Policy: Learn the Policy Inside and Out. Register online at bit.ly/aopawebinars. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.

Webinar Conference

Who’s on First? Medicare as a Secondary Payer. Register online at bit.ly/aopawebinars. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.

Webinar Conference

August 12

Off-the-Shelf vs. Custom Fit: The True Story. Register online at bit.ly/aopawebinars. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.

Webinar Conference

September 9

Prior Authorization, How Does It Work? Register online at bit. ly/aopawebinars. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.

Webinar Conference

October 7-10 98th AOPA National Assembly. The Henry B. Gonzalez Convention Center, San Antonio, TX. More information at bit.ly/2015assembly. For exhibitors and sponsorship opportunities, contact Kelly O’Neill, 571/4310852, or koneill@AOPAnet.org. General inquiries, contact Betty Leppin at 571/431-0876 or bleppin@AOPAnet.org.

April 12-14

AOPA: Mastering Medicare Essential Coding & Billing Techniques Seminar.

Grand Hyatt Seattle, Seattle, WA. Register online at bit. ly/2015billing. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.

April 30-May 2

2015 International African-American Prosthetic Orthotic Coalition Annual Meeting. Ocean Front Studio Suites, Virginia Beach, VA. Contact Michael Smith at 757/548-5656, email aopcnow@gmail.com, or visit www.iaaopc.org.

May 13

The New Player in Town: Understand How the RAC Contract Works. Register online at bit.ly/aopawebinars. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.

Webinar Conference

46

DECEMBER 2014 | O&P ALMANAC

October 14

Understanding the LSO/TLSO Policy. Register online at bit.ly/ aopawebinars. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.

Webinar Conference

November 11

How To Make a Good Impression: Marketing Yourself to Your Referrals.

Register online at bit.ly/aopawebinars. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.

Webinar Conference

December 9

Bringing the New Year: New Codes and Changes for 2016. Register online at bit.ly/aopawebinars. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.

Webinar Conference

ADVERTISERS INDEX

Company

Page Phone

Website

ALPS South LLC

13

800-574-5426

www.easyliner.com

College Park Industries

7

800-728-7950

www.college-park.com

DAW Industries

1, C3

800-252-2828

www.daw-usa.com

Dr. Comfort

5

877-713-5175

www.drcomfort.com

Ferrier Coupler Inc

17

810-688-4292

www.ferrier.coupler.com

Fillauer

9

800-251-6398 www.fillauer.com

FLO-TECH O*P SYSTEMS, INC

27

800-356-8324

Hersco

2

800-301-8275 www.hersco.com

www.1800flo-tech.com

Ottobock

C4

PEL

C2 800-321-1264 www.pelsupply.com

800-328-4058 www.professionals.ottobockus.com

AMERICAN ORTHOTIC & PROSTHETIC ASSOCIATION

BUSINESS OPTIMIZATION ANALYSIS TOOL (BOAT) AOPA’s largest and most successful members use the BOAT. The BOAT will help you:

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business owners manage their business for GREATER PROFIT AND QUALITY PATIENT CARE. If you do not already have a BOAT account, contact AOPA’s BOAT partner, Michael Becher, Industry Insights, 614/389-2100 x 114 or mbecher@ industryinsights.com, to enroll today.

Help you identify and

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O&P ALMANAC | DECEMBER 2014

47

ASK AOPA

Signature, Please Answers to your questions regarding prescription writing and hospital payments

AOPA receives hundreds of queries from readers and members who have questions about some aspect of the O&P industry.

Each month, we’ll share several of these questions and answers from AOPA’s expert staff with readers.

If you would like to submit a question to AOPA for possible inclusion in the department, email Editor Josephine Rossi at jrossi@contentcommunicators.com.

Q

If a nurse practitioner is writing a prescription, he or she also must meet four criteria. First, the nurse practitioner must be treating the beneficiary for the condition for which the item or service is required. Second, he or she must be practicing independently of a physician. Third, he or she must have his or her own NPI number and must be billing Medicare for other covered services using that NPI number. Finally, he or she must be permitted to practice in the state in which he or she is providing services.

Are physician assistants or nurse practitioners eligible to write and sign prescriptions, and document the need for Medicarecovered items and service?

If a doctor orders an orthosis or prosthesis during an inpatient stay and I provide it, can the facility refuse to pay me? If the facility refuses to pay me and the patient is willing to pay for the item, may I bill the patient?

Yes. Physician assistants and nurse practitioners may be the ones to document the need for Medicare-covered benefits, and they also are eligible to write prescriptions (i.e., the initial order and the detailed order). However, there are a few caveats when a physician assistant or nurse practitioner is writing the prescriptions.

If a physician assistant is writing a prescription, he or she must meet four criteria. First, he or she must meet the definition of physician assistant found in the Social Security Act. Second, he or she must treat the patient for the condition for which the item or service ordered is needed. Third, he or she must be working under the supervision of a doctor of medicine or doctor of osteopathy. Fourth, he or she must have his or her own National Provider Identifier (NPI) number and must be allowed to practice in the state where he or she is working.

Unfortunately, the answer is yes and no.

Yes, the facility can refuse to pay you.

Since the facility has the responsibility to provide all medically necessary care during a Medicare Part A covered stay, and the facility is receiving a per diem payment from Medicare to provide all medically necessary care, the facility may choose the vendor that provides the care. If a physician provides you with an order and you provide the item without authorization from the facility, the facility may not be obligated to pay you.

This is not a Medicare issue, but more of a contractual issue. Since the facility is ultimately responsible for providing the care, that facility may decide who they want to provide that care. While there may be legal precedents in some states that would require the facility to pay for the service, as a general rule, the hospital has the right to decide who it selects

Q/

A/

48

DECEMBER 2014 | O&P ALMANAC

Q/

A/

as its vendors and business partners.

No, you may not bill the patient for the item, even if he or she is willing to pay for it. Since the facility or hospital is receiving a per diem payment from Medicare to provide all covered items and services, the item already has been paid for, and billing the patient would mean that the item was paid for twice.

Do rehab hospitals follow the same rules as acute care hospitals and other types of hospitals?

Q/

Yes. Even though rehab hospitals are paid under a separate Prospective Payment System than acute hospitals, the rules regarding the rehab hospital’s responsibility to provide or pay for medically necessary care remain exactly the same as they are for acute care hospitals. From the O&P provider’s perspective, the same payment rules that apply to acute care hospitals also apply to rehab hospitals.

A/

If an orthotic or prosthetic item is provided to a patient in the emergency room (ER) and the patient is not admitted to the hospital, may I bill Medicare? What if the patient is admitted to the hospital?

Q/

If the patient is not admitted to the hospital, you may bill Medicare for the items provided during the ER visit because ER visits are covered by Medicare Part B. If the patient is immediately admitted to the hospital following the ER visit, then the hospital must pay for the item. However, keep in mind that the hospital could refuse to pay you if it didn’t provide a purchase order.

A/

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