THE MAGAZINE FOR THE ORTHOTICS & PROSTHETICS INDUSTRY
The American Orthotic & Prosthetic Association
Compliance Corner Column Page 28
The Path Forward
Experts share insight on challenges, opportunities in the New Year
THE NEXT GENERATION of O&P providers NEW HCPCS CODES, descriptor changes for 2014
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O&P JANUARY 2014, VOLUME 63, No. 1
CONTENTS Cover Story
16 O&P’s Path Forward
By Adam Stone The “new normal” for the O&P industry is an everfluctuating environment rife with issues related to RAC audits, competitive bidding, health-care reform, and new technologies. AOPA leadership and industry experts discuss how to navigate the landscape in 2014 and beyond.
22 The Next Generation of O&P Practitioners
By Christine Umbrell Practitioners of the future will need a different skill set than in years past. Fortunately, many O&P schools are preparing students to be more science-minded and well-rounded to deliver the kind of O&P care that will be needed.
AOPA Contact Page How to reach staff
At a Glance Statistics and O&P data
In the News Research, updates, and company announcements
Reimbursement Page New HCPCS codes and descriptor changes for 2014
Compliance Corner HIPAA compliance tips to avoid costly fines Facility Spotlight SRT Prosthetics & Orthotics
AOPA Headlines News about AOPA initiatives, meetings, member benefits, and more
42 AOPA Membership 00 Applications
Products and services for O&P Opportunities for O&P professionals
Upcoming meetings and events
AOPA Answers Expert answers to your FAQs
O&P Almanac (ISSN: 1061-4621) is published monthly by the American Orthotic & Prosthetic Association, 330 John Carlyle St., Ste. 200, Alexandria, VA 22314; 571/431-0876; fax 571/4310899; 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. Postmaster: Send address changes to: O&P Almanac, 330 John Carlyle St., Ste. 200, Alexandria, VA 22314.
JANUARY 2014 O&P Almanac
AOPA IN THE Contact NEWS INFORMATION 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 EXECUTIVE OFFICES
MEMBERSHIP & Meetings
BOARD oF DIRECTORS
Thomas F. Fise, JD, executive director, 571/431-0802, tfise@AOPAnet.org
Tina Moran, CMP, senior director of membership operations and meetings, 571/431-0808, tmoran@AOPAnet.org
Don DeBolt, chief operating officer, 571/431-0814, ddebolt@AOPAnet.org
Maynard Carkhuff Freedom Innovations, LLC, Irvine, CA
Kelly Oâ€™Neill, CEM, manager of membership and meetings, 571/431-0852, koneill@AOPAnet.org
President Anita Liberman-Lampear, MA University of Michigan Orthotics and Prosthetics Center, Ann Arbor, MI
O&p Almanac Thomas F. Fise, JD, publisher, 571/431-0802, tfise@AOPAnet.org Josephine Rossi, editor, 703/914-9200 x26, firstname.lastname@example.org Catherine Marinoff, art director, 786/293-1577, email@example.com Bob Heiman, director of sales, 856/673-4000 firstname.lastname@example.org Lia K. Dangelico, managing editor and contributing writer, 703/914-9200 x24, email@example.com Stephen Custer, production manager, 571/431-0810, scuster@AOPAnet.org Christine Umbrell, editorial/production associate and contributing writer, 703/914-9200 x33, firstname.lastname@example.org
Stephen Custer, communications manager, 571/431-0810, scuster@AOPAnet.org Lauren Anderson, manager of membership services, 571/431-0843, landerson@AOPAnet.org Betty Leppin, project manager, 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
President-Elect Charles H. Dankmeyer Jr., CPO Dankmeyer Inc., Linthicum Heights, MD Vice President James Campbell, PhD, CO Becker Orthopedic Appliance Co., Troy, MI Immediate Past President Tom Kirk, PhD Member of Hanger Inc. Board, Austin, TX Treasurer James Weber, MBA Prosthetic & Orthotic Care Inc., St. Louis, MO Executive Director/Secretary Thomas F. Fise, JD AOPA, Alexandria, VA
Devon Bernard, assistant director of coding reimbursement, programming and education, 571/431-0854, dbernard@AOPAnet.org Reimbursement/Coding: 571/431-0833, www.LCodeSearch.com
Jeff Collins, CPA Cascade Orthopedic Supply Inc., Chico, CA Alfred E. Kritter Jr., CPO FAAOP, Hanger, Inc., Savannah, GA Eileen Levis Orthologix LLC, Trevose, PA Ronald Manganiello New England Orthotics & Prosthetics Systems LLC, Branford, CT Dave McGill Ă–ssur Americas, Foothill Ranch, CA Michael Oros, CPO Scheck and Siress O&P Inc., Oakbrook Terrace, IL Scott Schneider Ottobock, Minneapolis, MN Don Shurr, CPO, PT American Prosthetics & Orthotics Inc., Iowa City, IA
O&P Almanac Publisher Thomas F. Fise, JD Editorial Management Stratton Publishing & Marketing Inc. Advertising Sales RH Media LLC Design & Production Marinoff Design LLC Printing Dartmouth Printing Company
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 Almanac. The Almanac is not responsible for returning any unsolicited materials. All letters, press releases, announcements, and articles submitted to the 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.
O&P Almanac JANUARY 2014
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AT IN THE A GLANCE NEWS
Rise of O&P Technicians, Assistants, and More The number of O&P “extenders of care” is expected to grow as more O&P schools offer courses for technicians, assistants, orthotic fitters, and more. Last September, a consortium of five O&P schools was awarded $11.2 million as part of the Trade Adjustment Assistance Community College and Career Training (TAACCCT) grant program, to be used to expand and improve O&P career education by increasing the attainment of industry-recognized credentials. Here’s a breakdown of where the funds went.
U.S. Colleges and Universities Receive TAACCCT Grants to Boost O&P Career Education $1.4
Baker College (Flint, Michigan)
illio $1.4 m
Spokane Falls Community College (Spokane, Washington)
n millio $1.7
Oklahoma State University Institute of Technology (Okmulgee, Oklahoma)
St. Petersburg College (St. Petersburg, Florida)
n $4.7 millio
Century College (White Bear Lake, Minnesota)
Total: $11.2 million Source: U.S. Department of Labor news release, Sept. 18, 2013.
Number of orthotic fitters certified by BOC.
Number of O&P technicians certified by ABC.
Number of orthotic fitters certified by ABC.
Amount of orthotic fitting experience required before a candidate may take the ABC or BOC certification exam for orthotic fitter.
1,900 hours Amount of clinical experience required before a candidate may sit for the ABC certification exam as a certified O&P assistant.
Sources: The American Board for Certification in Orthotics, Prosthetics, and Pedorthics; the Board of Certification/Accreditation; and the National Commission on Orthotic & Prosthetic Education. 6
O&P Almanac JANUARY 2014
Number of NCOPEaccredited schools offering O&P technician education courses.
For more on the growth of collegiate programs, read the sidebar in “The Next Generation of O&P Practitioners” on p. 22.
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IN THE NEWS
Legislation Would Protect Injured and Amputee Veterans Congresswoman Renee Ellmers (R-North Carolina) has introduced HR 3408, the Injured and Amputee Veterans Bill of Rights, which would help protect key rights of this demographic, including: • access to appropriate O&P technology to meet individual veterans’ needs • ability to receive care from a private O&P practitioner of choice (the vast majority of veterans receive prosthetic care through 600 contracts with private O&P practitioners) • a second opinion from Veterans Administration (VA) medical personnel as to O&P treatment options • a functional spare prosthetic limb or orthotic brace • timely and efficient prosthetic and orthotic care.
Veterans currently have these rights, but there is wide variation and inconsistency across the country as to how these rights are implemented at the regional and local levels. This bill educates veterans as to their rights and expectations for quality VA O&P treatment. The bill is designed to empower veterans to advocate for themselves so they can obtain the most appropriate care.
Worldwide Diabetes Rate Reaches All-Time High
The number of people estimated to be living with diabetes reached a new record of 382 million people in 2013, up from 371 million in 2012. This estimate is equivalent to a prevalence rate of 8.4 percent of the adult population, according to the International Diabetes Federation (IDF). Given current conditions, IDF predicts the number of cases to increase by 55 percent by the year 2035, up to 592 million. The majority of the diabetes cases are type 2, which is linked to obesity and a lack of exercise. The number of people with type 2 diabetes is rising in every country, according to the IDF. Experts say the epidemic is spreading as more people adopt Western, urban lifestyles. “The battle to protect people from diabetes
O&P Almanac JANUARY 2014
and its disabling, life-threatening complications is being lost,” the IDF reported in Diabetes Atlas, Sixth Edition. Diabetes accounts for annual health-care spending of $548 billion—and that number is expected to rise to $627 billion by 2035, according to the IDF. Looking at diabetes rates by country, China has the most diabetics overall, but the highest prevalence rates are in the Western Pacific. More than a third of adults in Tokelau, Micronesia, and the Marshall Islands are currently living with diabetes. Eighty percent of people with diabetes live in low- and middle-income countries, reports the IDF. Download the book at www.idf.org.
2014 da Vinci Awards Now Accepting Nominations The 2014 da Vinci Awards program is seeking nominations to honor those who bring life-improving technologies to the world. The da Vinci Awards recognize innovative developments and research in adaptive and assistive technology, and innovations that enable all people to function at their fullest. Nominations are being accepted online through January 31 at www. davinciawards.com in five categories: Prosthetics/Orthotics/Controls; Communication/Educational Aids; Environmental Adaptation/Daily Living or Work Aids; Transportation and Mobility; and Recreation/Leisure/ Rehabilitation/Fitness. Winners will be announced in April.
IN THE NEWS
PAD Treatments May Not Reduce Amputation Rates Medicare spending on patients with peripheral artery disease (PAD) varies by location, but increased spending does not result in a significant difference in amputation rates, according to a new study. Led by Philip Goodney, MD, of the Dartmouth-Hitchcock Medical Center in Lebanon, New Hampshire, a research team analyzed data from more than 18,400 Medicare beneficiaries who underwent major PAD-related amputations between 2003 and 2010. Results indicated regional costs ranged from $11,077 in Bismarck, North Dakota, to $42,613 in Salinas, California. Goodney’s team found that the study “offers little evidence to suggest that more expensive vascular care offers a marginal advantage over less expensive vascular interventions,” according to a study published in JAMA Surgery. Amputation rates were similar regardless of whether revascularizations had been done.
Researchers concluded that while the amputation rate for PAD was similar despite the wide variances in costs across regions, it’s important to remember that revascularizations have beneficial outcomes for some patients.
OIG Releases Report Critical of Jurisdiction B DME MAC Claim Payments The Office of Inspector General (OIG) has released a report that concluded that National Government Services (NGS), the Jurisdiction B Durable Medical Equipment Medicare Administrative Contractor (DME MAC), inappropriately paid claims totaling $1.5 million for lower-limb prostheses that did not meet the requirements outlined in the Local Coverage Determination (LCD) in effect at the time. The report addressed claims from Jan. 1, 2009, through Sept. 30, 2012, and involved 770 total claim lines of service. OIG reported that 682 claim lines should have been denied due to missing or incorrect functional level modifiers, and 88 claim lines should have been denied due to impermissible combinations of base and addition codes. While the report
was not directly critical of providers of lower-limb prostheses, reports of this nature are intended to, and usually generate, a reactionary response from the contractors that typically results in increased audit activity. OIG recommended that NGS take immediate action to recoup the improper payments and ensure that proper claim edits are in place to prevent similar improper payments going forward. NGS responded by indicating that recoupment has already occurred on the majority of the claims that OIG identified, and that system edits have been implemented to prevent the continued improper payment of claims. The 770 claim lines identified by OIG represented less than one tenth of 1 percent of the 529,351 claim lines
for lower-limb prostheses processed by NGS during the review period. In addition, all of the claim lines identified should have been denied according to the LCD requirements in place at the time. None of the claims were reviewed for individual medical necessity; they were only reviewed to determine if the correct functional level modifier for the specific procedure code was reported or if base code/addition code combinations were submitted that were specifically not permissible according to the LCD. To download a copy of the report, visit www.oig.hhs.gov/oas/reports/ region7/71305039.pdf. Questions regarding the OIG report may be directed to Joe McTernan at jmcternan@ aopanet.org or Devon Bernard at email@example.com.
JANUARY 2014 O&P Almanac
IN THE NEWS
Virtual World for Amputees Under Development at Florida University Sandra Winkler, PhD, a faculty researcher and assistant professor at Nova Southeastern University College of Health-Care Sciences in Fort Lauderdale, Florida, has been awarded a three-year, $1 million grant to develop a virtual world program to support amputees. The grant was awarded in response to Winkler’s research, “Dissemination of Amputation and Prosthetic Evidence-Based Medicine.” Winkler has created virtual islands that host educational and supportive programs, with the goal of disseminating evidence-based information in a peer network where amputees help each other, train clinicians, and offer emotional support to peers. Virtual Health Adventures consists of four islands in the Second Life® program. Participants in the study will go online to visit the islands to simulate what it is like to once
again use their missing limbs. In addition to virtual recreational activities such as jet skiing and diving, the virtual world will offer a historical tour of prosthetics, educational seminars, and a virtual shop where participants can “test” prosthetic models. The grant for this project was awarded by the U.S. Department of Health & Human Services Agency for Healthcare Research & Quality. More information about the study is available at www.virtualhealthadventures.org.
Important 2014 HCPCS Code/ Competitive Bidding Update The Centers for Medicare and Medicaid Services (CMS) has released the 2014 update for the Healthcare Common Procedure Coding System (HCPCS). This update includes all new, changed, and deleted HCPCS codes that will be implemented for claims with a date of service on or after Jan. 1, 2014. For O&P services, the update includes 24 new codes, 63 codes that have had their descriptors changed, and one deleted code. This represents a significant number of changes in the O&P code set and represents a new reality for O&P providers, specifically in relation to 23 services that have been split into two categories: orthoses that are provided “off the shelf” (OTS) with no additional fitting and training, and those that are “customized to fit a specific patient by an individual with expertise.” The August 2013 release of CMS’s final OTS list served as a clear indication of what was to come. In this release, CMS provided responses to AOPA’s and other organizations’ concerns regarding the original OTS list. The final list contained 32 codes that would always be considered OTS and proposed the split of 23 codes into OTS versions and customfit versions. The creation of the split codes essentially sets the stage for CMS to include HCPCS codes that include the term “off the shelf” in their descriptors in a future round of competitive bidding. AOPA has voiced its concerns regarding CMS’s expansion of the term “off the shelf” from the statutory definition, which requires “minimal self-adjustment,” to include adjustments provided by the “beneficiary, caregiver, or supplier” through multiple meetings and correspondence with CMS officials.
O&P Almanac JANUARY 2014
Unfortunately, as indicated by the release of the 2014 HCPCS file, AOPA’s concerns continue to fall on deaf ears. While the potential for inclusion of OTS orthoses in future rounds of competitive bidding is a major concern for the O&P profession, indications to date have been that it is not imminent and may be months or possibly years away. A larger concern is how the split codes may affect an O&P provider’s ability to bill and receive proper reimbursement for orthoses that require the expertise and professional training of an O&P professional to prevent potential harm to patients. Essentially, there are now two ways to deliver the 23 orthoses that have had their codes split: those provided without any fitting and training, and those that are customized to fit a specific patient by an individual with expertise. The question that has now been created is: Who will make the decision whether an orthosis requires proper fitting by a trained individual or can be delivered as an OTS item without additional fitting and training? AOPA members must be cognizant of the need to document the medical necessity for additional fitting and training as well as the actual time spent customizing the device to meet the individual needs of the patient. The referring physician also should be encouraged to document the need for additional training and fitting as well. Visit www.aopanet.org/2014HCPCSCodeChanges.pdf to see the code changes. To access the CMS OTS list or learn more about the competitive bidding overview, contact Joe McTernan at firstname.lastname@example.org or Devon Bernard at email@example.com.
IN THE NEWS
Deadline Extended for 2014 Medicare Open Enrollment Period The deadline to change your participation status with Medicare for 2014 has been extended and will end on Jan. 31, 2014, instead of Dec. 31, 2013. The open enrollment period is your only opportunity to change your Medicare participation status for 2014. If you elect to be a participating provider, your company will be listed in the Medicare provider directory, any claims involving a Medigap supplement policy will be automatically crossed over by the Durable Medical Equipment Medicare Administrative Contractors, and you will be paid directly by Medicare. However, as a participating provider, you agree to accept assignment on all Medicare claims as long as the participation agreement remains in effect, and therefore you can never bill any balances. If you choose to be nonparticipating, you may decide on a claim-by-claim basis whether you will accept assignment. This status allows you to collect your full charge on non-assigned claims, even if it exceeds Medicare’s allowable.
Some Medicare Claims Will Be Subject to Edits The Centers for Medicare and Medicaid Services (CMS) has announced that Medicare claims with a date of service on or after Jan. 6, 2014, will be subject to edits that will ensure that the referring/ordering physician has an active profile in the Provider Enrollment Chain Ownership System (PECOS). Claims where there is no PECOS record for the referring/ ordering physician will be denied. The Affordable Care Act established the PECOS requirement for referring providers, but implementation has been delayed. Since 2009, claims that involved a non-PECOS enrolled physician have been processed with a warning message that the referring provider is not in PECOS. As of Jan. 6, 2014, these claims will be denied. a
If your company has a participation agreement in effect for 2013 and you wish to be nonparticipating for 2014, you must submit a written notice to the National Supplier Clearinghouse (NSC), postmarked by Jan. 31, 2013. The letter must have an original signature of your office’s authorized representative on file with the NSC. The letter should be sent to: National Supplier Clearinghouse P.O. Box 100142 Columbia, SC 29202-3142 If you are currently enrolled in Medicare as a nonparticipating provider and you wish to change your company’s status to a participating provider, you must complete a Medicare Participation Agreement for 2014, form CMS 460. Contact Devon Bernard at dbernard@AOPAnet.org or 571/431-0854, or Joe McTernan at jmcternan@AOPAnet.org or 571/431-0811, with any questions.
BUSINESS in the news
Hanger Inc.’s board of directors has elected Christopher B. Begley, retired executive chairman of the board of directors and former chief executive officer of Hospira, to join the Hanger board as a director.
Melissa Stockwell, CP, a Paralympic swimmer and paratriathlete, and a practitioner at Scheck & Siress, has been honored with the Wilma Rudolph Courage Award from the Women’s Sports Foundation.
Curt A. Bertram, CO, FAAOP, has assumed the role of president of the board of directors of the American Board for Certification in Orthotics, Prosthetics, and Pedorthics. John Craig, CPO, LPO, has been appointed to the board of directors of Limbs International in El Paso, Texas.
JANUARY 2014 O&P Almanac
Reimbursement Page By Joe McTernan, AOPA government affairs department
New Year, New Challenges Key information about HCPCS codes and descriptor changes in 2014
his year brings with it the largest number of changes to the O&P Healthcare Common Procedure Coding System (HCPCS) code set in many years. A total of 24 new codes are being introduced, along with descriptor changes for 63 codes and a single code deletion. A complete list of all of the HCPCS changes scheduled for implementation on Jan. 1, 2014, is available on AOPA’s website at www.aopanet. org/2014HCPCSCodeChanges.pdf.
The majority of new and changed codes are a direct result of a single but very important issue: the separation of prefabricated orthoses into those that are considered to be “off the shelf” and those that require the expertise of a trained individual in order to be fit properly. 12
O&P Almanac JANUARY 2014
At a glance, these changes seem overwhelming by volume alone but when they are examined closer, a larger picture comes into focus. The majority of new and changed codes are a direct result of a single but very important issue: the separation of prefabricated orthoses into those that are considered to be “off the shelf” (OTS) and those that require the expertise of a trained individual in order to be fit properly. This change is a direct result of Centers for Medicare and Medicaid Services (CMS) efforts over the last 18 months to define which orthotic services can be delivered as OTS and, therefore, be subject to future rounds of competitive bidding. AOPA has been very active in communicating its concerns to CMS regarding the overly broad regulatory definition of OTS orthoses. The statutory definition of OTS orthoses as recorded in Section 1847 (a)(2) of the Social Security Act is “those which require minimal self-adjustment for appropriate use and do not require expertise in trimming, bending, molding, assembling, or customizing to fit to the individual.” In regulations published at 42 CFR 414.40, CMS defined the term “minimal self-adjustment” as “an adjustment that the beneficiary, caretaker for the beneficiary, or supplier of the device can perform and that does not require the services of a certified orthotist (that is, an individual who is certified by the American
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The creation of new OTS codes, split codes, and verbiage changes to differentiate OTS codes from codes that require expertise in fitting all have potential consequences on medical policy.
Board for Certification in Orthotics, Prosthetics & Pedorthics, or by the Board of Certification/Accreditation) or an individual who has specialized training.” AOPA believes that the regulatory expansion of OTS devices through the definition of the term “minimal self-adjustment” greatly exceeds the intent of the statutory language in classifying OTS orthoses that are subsequently eligible for inclusion in future rounds of competitive bidding. Despite AOPA’s repeated communication—both in person and in writing—regarding the potential harm to patients that may result from the delivery of certain orthoses without proper fitting, adjustment, and clinically based follow-up care, CMS has elected to move forward with all of the proposed changes to the HCPCS code set that it published in August of 2013.
Questions Remain While the implementation of competitive bidding for OTS orthoses does not appear to be imminent, the potential for immediate impact on Jan. 1, 2014, remains a real possibility. The questions are endless and the answers
O&P Almanac JANUARY 2014
are few. With the creation of “split” codes that essentially describe the same device—one provided without any additional fitting by a properly trained individual and one provided with appropriate fitting by a qualified individual—the natural question is, who will make the determination regarding the need for clinically based care to ensure the proper function of the device? In addition to determining the need, what documentation will be required to support claims for services that require proper fitting by a qualified individual? AOPA is very concerned about how the Durable Medical Equipment Medicare Administrative Contractors (DME MACs) will react to these coding changes. The creation of new OTS codes, split codes, and verbiage changes to differentiate OTS codes from codes that require expertise in fitting all have potential consequences on medical policy. While CMS owns the HCPCS level II code set and, therefore, has the right to alter it, the DME MACs have the responsibility to develop appropriate medical policies regarding the coverage criteria that must be met in order to justify claim
payment. With a large number of coding changes and the creation of an entirely new subset of prefabricated orthoses (OTS), there is a need for medical policy that will govern when items should be delivered as OTS and when the items require fitting by an individual with expertise. By design, medical policy is supposed to clearly identify when services are covered by Medicare or deemed as not medically necessary. The creation of medical policy involves a process that will take significantly more time than the code implementation date of Jan. 1, 2014. The question that must be asked is, if policy does not exist, who makes the decisions regarding medical necessity? Is each claim reviewed manually? Will policy, once it is developed, be applied retroactively? What is the role of the Pricing, Data Analysis, and Coding (PDAC) contractor in all of this? The PDAC is charged with verifying coding for existing products as well as products recently introduced to the marketplace. As policy requires PDAC determinations for many of the codes in question, will PDAC revise its existing coding verifications for these products? Another AOPA concern that appears to have been answered—at least in the short term—involves the Medicare fee schedule for the new and revised codes. The natural assumption was that the fee schedule for the OTS codes would be set significantly lower than the existing fee schedule for the HCPCS codes that described identical items requiring custom fitting by a trained individual. With the release of the 2014 Medicare Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) fee schedule on Dec. 12, 2013, CMS elected to set the allowable amounts for the OTS codes at the same level as the existing fees for the custom fit codes, including the 1 percent annual update. This created an entirely new question. The logical assumption is that once the OTS codes are subject to competitive bidding, the fee schedule for those codes will be
reduced as part of the bidding process. It is not beyond possibility, however, that CMS will revisit this issue prior to Jan. 1, 2014, and revise the DMEPOS fee schedule to reflect lower allowable for the OTS codes. Finally, AOPA remains concerned about how the introduction of a split code set may affect audits, especially Recovery Audit Contractor (RAC) audits. With RAC auditors highly incentivized to identify and recover overpayments, it seems that the confusion over when to bill for an orthosis using an OTS code and when to bill using a non-OTS code sets the stage for significant RAC activity down the road. The establishment of identical fee schedule amounts for the OTS and custom fit versions of the split codes only increases the potential scrutiny of suppliers who choose to utilize custom fit codes to describe the services they are providing. With no definitive answers regarding what, how, and when to document the need
for customized fitting of orthoses, confusion will only increase exposure for providers who are simply doing their best to provide the best level of care for their patients. AOPA is developing strategies as we speak to address these and other questions that have arisen as a result of the creation of the new OTS codes. While there appear to be more questions than answers at the moment, AOPA will continue to work tirelessly
to ensure that the best interests of its members are properly represented and that, ultimately, the Medicare beneficiary population will not suffer due to a reduced level of clinical care in the provision of orthoses. a Joe McTernan is director of reimbursement services at AOPA. Reach him at firstname.lastname@example.org.
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JANUARY 2014 O&P Almanac
RAC audits RAC audits
O&P Almanac JANUARY 2014
COVER STORY By ADAm STONE
Forward AOPA leadership, experts share insight on what lies ahead for the industry
ave no illusions. As 2014 dawns, the changes sweeping across the health-care landscape will touch every aspect of O&P practice. New regulations, new technologies, the seemingly endless uphill battle for fair and balanced Medicare audits—these and more will be woven into the fabric of O&P care. “In the health-care world of the next few years, patients who do not take the trouble to fully understand what is going on with their care will be left behind—and the same is true for providers,” says AOPA Executive Director Tom Fise. “It is all going to get much more complicated, all in the name of saving money.” Against this backdrop of upheaval, O&P practitioners face special challenges. They must simultaneously address a range of issues surrounding Medicare audits, evolving technologies, reimbursement structures, and a host of other business issues integral to successful practice management and positive patient outcomes. Here we present the top five issues O&P providers will likely face in the coming year.
JANUARY 2014 O&P Almanac
Audits Evolving The Recovery Audit Contractor (RAC) program remains the dominant issue on the table for many in O&P. The program seeks redress in suspected cases of Medicare fraud and abuse, and it claims to have recouped billions in apparently erroneous billings. But that’s not the whole story. Many in O&P say aggressive auditing has put their practices in financial jeopardy, threatening the quality of patient care, along with providers’ ability to deliver that care. “[Audits] are affecting everybody right now. It is literally putting people out of business by disrupting their cash flow,” says Joe McTernan, director of coding and reimbursement, programming and education at AOPA. “[Audits] are not slowing down and if anything they are increasing, with new auditors being added into the system as we speak,” says McTernan. He pointed for instance to the recently added Supplemental Medical Review Contractor, whose initial mission was limited to power wheelchair claims. “The assumption is that at some point they will be shifting into other areas where there is the perception of high levels of inappropriate claims.” This will likely mean even more O&P audits. Evidence suggests the already oppressive audit situation will be getting worse and not better in the immediate future. For example, Össur Vice President Dave McGill noted that while auditors have focused primarily on K3-level claims up to now, there is a trend toward increased examination of K2 cases, thus broadening the possible scope of investigations. At the same time, practitioners have to wait longer than ever for the chance to appeal audit results, with some waiting as long as two years to get to a hearing. “You have to ask: Will there even be a business there to appeal two years from now?” says McGill. The ongoing challenge of audits should put practitioners on alert that the old ways of doing business may no longer be sufficient. “There is a new normal and people need to change their behaviors,” says AOPA President Anita Liberman-Lampear. 18
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“In the health-care world of the next few years, patients who do not take the trouble to fully understand what is going on with their care will be left behind— and the same is true for providers.” —Tom Fise “You need to be documenting your cases, getting all the information you should have in your medical records, and getting the right information from your physicians.” Such documentation—detailed, explicit, and thorough—will be the front line of defense in case of an audit. AOPA and the O&P Alliance have met with the Centers for Medicare and Medicaid Services (CMS) on numerous occasions to express concern that the current off-the-shelf (OTS) list may have a negative impact on the quality of care received by Medicare beneficiaries. While CMS has been willing to meet, based on the 2014 Healthcare Common Procedure Coding System (HCPCS) code release, it has chosen not to heed the concerns presented during these meetings. After exhausting all administrative remedies regarding the predatory behavior of RAC auditors, AOPA had no choice but to file a lawsuit against CMS in federal district court, and did so May 13, 2013. The government responded with a motion to dismiss, claiming that the federal district court did not have jurisdiction to hear the case. AOPA responded to the government motion to dismiss, requesting that the judge allow oral arguments to be heard regarding the motion to dismiss. AOPA is awaiting the judge’s decision on these matters.
Competitive Bidding In another arena, O&P advocates will continue this year to wrangle with plans by the Department of Health and Human Services (HHS), Office of the Inspector General, to classify back orthoses as OTS items. If implemented, this scheme could classify these custom items as commodities and subject them to competitive bidding. “It is not happening yet but it is very close on the horizon,” says McTernan. Despite hundreds of pages of documentation from AOPA, rule makers continue to press forward with competitive bidding, a plan that could have significant negative impact. “If [the government] goes to competitive bidding with the list as it is now, you will see a severe impact on access to care, since only certain suppliers will be able to provide these services.” Some would argue that the recent massive HCPCS recoding for orthotic devices is not a prelude to competitive bidding, but a substitute for competitive bidding. The unprecedented “dual coding” for the same device—one offered with clinical care and the other without—can trigger significant savings for CMS by setting inappropriately low allowable amounts for the new “no clinical service” codes. Major savings can be instituted immediately and unilaterally by CMS without going through the process
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and affording any of the protections set forth in the competitive bidding statute; instead CMS may well have substituted an entirely new O&P fee schedule, one without the least scintilla of statutory authority. The net result will be a degradation of care for patients. “The patient ultimately will be suffering,” says McTernan. “It may save money on paper but what are you doing to your patient population by creating that availability vacuum?” Ultimately, the notion of commoditizing orthotic items, which are very different from the durable medical equipment items that have previously been subject to competitive bidding, is flawed, says Fise. There is a world of difference between a diabetic test strip, for example, and an orthosis that may require careful fitting, training, and ongoing adjustment.
Health-Care Reform As the coming year unfolds, the nation will continue to feel its way through health-care reform, maneuvering the complexities of the Affordable Care Act (ACA). Simply put: Much remains unknown. Yet certain fundamentals stand out. Small businesses will be under greater pressure to provide health coverage for their workers—and O&P will be no exception. Primarily small enterprises, O&P practices will feel the same pinch as other businesses looking for ways to comply with the new requirements. At the same time, O&P may glean some advantage through the law’s insistence on more comprehensive coverage. “There are a lot of political issues, a lot of real-world issues that have impacted people’s views of the ACA,” says Fise, “but, in theory, the ACA ought to give providers at least somewhat greater assurance that patients will actually be able to cover the costs of their care. It should reduce the amount of uncompensated care.” Still, while policies will improve in principle, it will be wise to read the fine print. “Before people treat, they better be doing their homework 20
O&P Almanac JANUARY 2014
on these policies,” says LibermanLampear. “People may have O&P coverage but providers still are going to have to be very financially astute to make sure they understand what that coverage is.” Even as deadlines have come and gone in recent months, some big questions within ACA remain unanswered. As McTernan notes, one of the chief criteria under ACA is that insurance must cover “essential health benefits.” But as of this writing, it has yet to be determined whether or not O&P is an essential benefit in all 50 states because HHS has delegated that decision to the individual states. AOPA has a comprehensive summary of benchmark plans in each state from which members can choose. Members should advocate for the benchmark plan in their state that includes O&P as an essential benefit. States running their own exchanges will need to write their
own definitions, and it isn’t clear when that might happen. AOPA leadership and many others believe that O&P will be part of essential health benefits because the statute enumerates that “rehabilitative and habilitative” benefits must be covered, but HHS’s approach has made the matter murkier rather than clearer.
Technological Advancements O&P technology has seen rapid advances in recent years, and 2014 will prove no exception. The rise of microprocessor controls in particular promises to create solutions that are more individualized and responsive to environmental input. With such progress comes a new set of challenges. Wars in Iraq and Afghanistan have put O&P to the test to create new solutions for a generation of wounded warriors. In light of this pressing need, “technology has been responsible for terrific advances in the therapies that
“There is a new normal and people need to change their behaviors. You need to be documenting your cases, getting all the information you should have in your medical records, and getting the right information from your physicians.” —Anita Liberman-Lampear
orthotists and prosthetists are able to offer to their patients,” says Fise. On the flip side, however, “new and better treatments tend to cost more, so there is always pushback from the payer side.” The newest technologies typically provide better outcomes, “but that can be hard to document, and even then the payers don’t want to pay more than they did for the old products,” adds Fise. Manufacturers may be especially hard pressed to balance the equation, driven on the one hand by the need to invest in future technologies, while at the same time held back by reimbursement uncertainties. “The industry is challenged to show that higher technologies lead to higher outcomes, such as to make it more cost effective in the long term,” says McTernan. Even putting aside financial considerations, O&P practitioners who seek new solutions still must endure the prolonged process of getting those solutions recognized in the CMS coding system. It can easily take a year or more for new technology to be given a code that will allow for billing a new technology. Providers can help move the needle by using consistent language when billing for products that don’t have codes, says McTernan. “If providers using a ‘miscellaneous’ code would use consistent language and describe the same thing over and over again, Medicare will actually track that data, and when they see hundreds of claims with that descriptor, they may start to recognize the need for a new code,” he says.
Practice Consolidation Practitioners may find themselves challenged by this broad range of outside influencers. At the same time, their own internal business needs will require continued care and attention. While running a sound enterprise has always been a priority, practice owners now must pay special care to
their business practices as momentum continues to build toward consolidation of independent practices across the O&P field. Several factors have come together lately to push for greater consolidation. First, there is the simple business logic at hand. As is true in virtually any industry, consolidation typically brings with it economies of scale, especially when it comes to merged back-office operations. By reducing overhead, a buyout or merger often will drive considerable operational savings. At the same time, health-care reform may be playing a role in shaping industry consolidation. The ACA has certain built-in elements that reward integrated systems of care. The more practitioners can team up—either through informal affiliations or through combining practices with different strengths—the more they may be able to meet this emerging standard. Those looking to join forces with a larger organization can take steps to position themselves, primarily by getting their paperwork in order, says McGill. “To be an attractive target, it’s not enough to have a history of providing decent care to a lot of patients. If your documentation is in a shambles you are going to be less attractive to acquirers, and if they do eventually buy you they will buy you for cents on a dollar.”
Looking Ahead Those are some of the biggest issues facing O&P today, but they are by no means the only challenges. Even
some lesser-heralded topics still carry weight. Look at therapeutic substitution, for instance. It’s hardly on the front burner, but it could become a game changer. As part of this policy, pharmacists may be allowed to swap out one medication for another—not a generic or even a drug in the same class, but a completely different type of drug directed to achieve the same effect as the drug the physician prescribed. Despite the fact that its mechanisms are different, it costs less and cost is king. The same principle could be applied to O&P. Fise describes a scenario in which the goal of post-amputation care is defined as “mobility.” Medicare might someday determine that a wheelchair meets that goal as well as any O&P therapy. “You could say that is farfetched but it’s not radically different in principle from what pharmacy benefit managers are already embracing,” says Fise. “I don’t know where this stops.” As this difficult climate persists, AOPA will continue its legislative efforts, including support of current legislation—the Medicare O&P Improvement Act (HR 3112); the Wounded Warrior Research Enhancement Act (S 521); the Insurance Fairness for Amputees Act (HR 3020); and others—aimed at improving treatment for amputees who receive care through the Medicare program or other federal agencies. Information regarding the current bills and draft letters to send your members of Congress are available at AOPAVotes.org. Certainly the immediate issues of the day provide plenty for the O&P community to chew on. But there are many unknowns out there, too—hills and valleys and rough places dotting a health-care landscape that promises to be anything but predictable in the coming months. a Adam Stone is a contributing writer to O&P Almanac. Reach him at adam. email@example.com. JANUARY 2014 O&P Almanac
By Christine Umbrell
The Next Generation of O&P Practitioners
How will the industry engage future providers to heed the call for care?
O&P Almanac JANUARY 2014
n the year 2030, what will the typical O&P practitioner look like? Amid growing concerns about the expanding need for O&P care in the United States as baby boomers age, many wonder whether there are enough qualified practitioners to fill the void left by retiring orthotists and prosthetists. As the profession evolves, with ever-more-technical devices hitting the shelves, and increasing federal oversight, O&P practitioners will need additional skills to succeed in this challenging environment. Fortunately, today’s O&P students are one step ahead of the game. As the realities of a new climate sink in, several O&P schools are using a number of strategies to train today’s students to maneuver future challenges, in hopes that they will be fully prepared to lead the profession into the next generation. Here’s a look at how industry experts believe the next generation of practitioners will evolve.
Though educators agree the need for O&P care is growing, they also agree that O&P schools are changing in the way they teach O&P candidates, and are adapting their programs to fit the dynamic landscape. “All of the models predict an aging population, and the need for care seems to be increasing,” says Jared Howell, director of the graduate program in O&P at Baylor College of Medicine’s School of Allied Health Sciences. “Overall, we may have an older population of clinicians, but we also have a lot of young people interested in the field,” adds Matthew Parente, CPO, PT, clinical director of the prosthetics and orthotics program at the University of Hartford. The new requirement for master’s level education prior to certification means a slightly different student population pursuing a degree in O&P. These students now must undergo a seven-and-a-half- to eight-year educational experience after high school—a more rigorous undertaking—but this also means students who choose the O&P education path are in it for the long haul, according to Parente. “Those who come into the University of Hartford as freshmen are very motivated,” he says.
More Educated Practitioners
Graduates from Northwestern University.
Staff at the Northwestern University Feinberg School of Medicine also have seen an evolution in the students who are applying to the O&P program. “The applicant pool has improved considerably in terms of the quality of institutions students attend for their undergraduate studies, majors of study, and undergraduate GPA,” says Christopher Robinson, CPO, MBS, MS, ATC, FAAOP. “Many applicants cite that they would not have taken interest in the profession had it not been elevated to an entry-level
master’s degree at the practitioner level. This opens the door to a quite a few individuals that would have historically disregarded orthotics and prosthetics in pursuit of a profession with a higher caliber of education.” Recent growth in the number of master’s level programs accredited by the National Commission on Orthotic & Prosthetic Education (NCOPE) is an indicator that supply is increasing to meet demand, says Robin Seabrook, NCOPE’s executive director. “We now have 13 master’s level programs, which is up from nine just four years ago,” she says. Three more schools are currently working with NCOPE to explore accreditation of master’s level programs, according to Seabrook. “Because the O&P degree is now master’s level, there’s great hope for the viability and sustainability of the profession.”
More Science-Minded Practitioners There has been a noted increase in the amount of science woven into the curriculum at O&P schools, so today’s students will be more science-minded when they become certified. With so many components available, “more education is required to understand the nuances of the devices, and the possibilities out there,” says Howell. JANUARY 2014 O&P Almanac
O&P Community College Programs Poised for Growth As the next generation of O&P prosthetists and orthotists prepares for a shifting climate within the O&P field, other levels of O&P care providers are adjusting as well. Educational programs for technicians, assistants, mastectomy fitters, and pedorthists are growing. Last September, a consortium of five O&P schools received a grant for $11.2 million as part of the Obama administration’s community college initiative, the Trade Adjustment Assistance Community College and Career Training (TAACCCT) grant program. The money is earmarked to “expand and improve the delivery of orthotics and prosthetics career education.” Century College in White Bear Lake, Minnesota—the “lead college” in the consortium—received $4.7 million to dedicate to the school’s O&P programs, primarily for technician-level education. In addition to funding staff, equipment, and technology to expand the school’s current programming, “the money will be used to develop curriculum among the five schools and put that curriculum online with high-tech methods of learning,” explains Kathy Bell, dean of nursing and allied health at Century. Equipment such as carvers, CAD equipment, and technology also are being purchased. Because O&P training is available in only a handful of schools, “we are taking a regional approach” to increasing access to technician-level
“The mindset in the past was that O&P was more art than science,” explains Parente. “Now we’re not eliminating the artistic side—but the science side is tipping a bit, with a heavier component of science.” For example, there is a greater focus on evidence-based research in the curriculum at the University of Hartford. “We need to validate O&P to payers using scientific research to support practitioners’ actions,” Parente explains. Incorporating this scientific aspect into the master’s level programs will “help establish more consistent lines of payment and show why what we’re doing works.” Having students focus on the outcomes aspect of their work will benefit the profession as a whole: “They’ll keep that scientific mindset into their residency, and into their practice once they become certified—and then they’ll teach that mindset to their residents,” predicts Parente.
“The mindset in the past was that O&P was more art
education, says Bell. “Online education has gotten quite advanced.” For
than science. Now we’re not
example, “if you live in the Dakotas, you could do online training first and
eliminating the artistic side—
then come here [to Century College] to complete the training.” At St. Petersburg College in Florida—which received $2 million in TAACCCT grant funds—part of the money will go toward creating new education programs, such as a two-week orthotic fitter course, a mastectomy course, and a pedorthic course, according to Arlene Gillis, program director. The school also is working on a new
but the science side is tipping a bit, with a heavier component of science.” —Matthew Parente, CPO, PT
baccalaureate degree for the O&P assistant level and is exploring adding a PhD program in conjunction with an area university. “We have a vision of a ‘career ladder’ within O&P; we are trying to stay ahead of the needs of the profession,” explains Gillis. One additional goal for all recipients of the O&P grant money is to raise awareness of the profession. “We are starting an awareness campaign for all of the levels we’re creating,” says Gillis. “We want to get the word out about all of these great options available.”
O&P Almanac JANUARY 2014
This shift to a more science-minded O&P practitioner base bodes well for the longevity of the field, says Parente. “If the payers stop paying, we’ll see fewer and fewer custom prostheses. So it’s critical that we continue to support our work with evidence-based practice and relevant clinical outcomes.”
More Well-Rounded Practitioners
AOPA Advances Student Education AOPA is doing its part to ensure the next generation of O&P is well-prepared for the changing industry. The organization has several programs in place intended to increase students’ exposure to all aspects of the O&P industry as part of their learning process. At each AOPA National Assembly, students are invited to attend and receive complimentary registration so they can participate in the educational programming and visit the Exhibit Hall to browse new O&P products and visit manufacturers. These students also are invited to a Student Social at each year’s Assembly, which is sponsored by the American Board for Certification in Orthotics, Prosthetics, and Pedorthics. “We average about 100-125 people at the event,” says Debbie Ayres, ABC’s director, public relations and marketing. “Our primary purpose for doing this is to enable students to meet professionals working in the field.” In addition, AOPA matches board members to O&P schools to serve as resources and foster lines of communication. For information about this program, contact Steve Custer at firstname.lastname@example.org.
“When compared to the medical community, our research truly is in its infancy stage,” says Parente. “As we continue to grow and have more research, we will see the maturation of the field. Evidenced-based practice and outcomes studies will really drive our future.” Parente sees current students as “reinforcements” for the current generation of practitioners, who are battling Medicare over increased audits and decreased reimbursements. Educating today’s practitioners to include more 26
O&P Almanac JANUARY 2014
outcomes-based measures within their practice serves as a supplement to the work AOPA and current practitioners are doing in fighting back against the increased audits. “AOPA needs to keep pushing back,” he says. “The seasoned veterans are putting up a good fight” and are beginning to use outcomes measures and evidence-based practice, which is important, says Parente. “Then we’ll bring in the reinforcements,” armed with more scientific data to support the critical work of orthotists and prosthetists.
As today’s practitioners learn the importance of managing both the clinical and business aspects of their businesses, they are teaching new practitioners to multitask. “The seasoned practitioner has demonstrated the need to be dynamic; the field of orthotics and prosthetics is constantly evolving with new technologies and a challenging regulatory environment,” explains Robinson. “The schools need to not only create a practitioner with the skills necessary to treat patients, but also sound-thinkers that have an effective framework for solving problems and findings practical solutions for their patients and practices.” The practitioner of tomorrow will need to be more well-rounded to face the challenges the profession is working through, says Robinson. “Clinicians need to have a stronger understanding for the interdisciplinary care models so that they can collaborate with other providers and eventually accountable care organizations; better assessment skills to evaluate the complex patients that are becoming more common to clinical practice; administrative skills to coordinate patient care while being fairly compensated; and the ability to integrate their personal experiences, their patients’ values and preferences, and the best available evidence to provide services with measurable benefits.”
More Models for Residency Completion Not only is the education aspect of O&P training evolving to meet the needs of the profession; so, too, is the residency program. Some of the practitioners of tomorrow will have gone through a slightly different residency experience than today’s practitioners. Currently, O&P students complete their master’s level education, then complete a 12-month residency (for one discipline) or an 18-month residency (for both orthotics and prosthetics), before they may take a certification
exam. However, one O&P school is turning this model upside-down. In its first year of offering a master’s level O&P program, Baylor has incorporated the O&P residency requirement directly into its curriculum—so students who graduate will already have fulfilled that requirement and will be ready to sit for a certification exam. The Baylor program spans two-anda-half years: 12 months of on-campus education courses, followed by 18 months of an O&P clinical residency, according to Howell. Unlike traditional residencies, where residents remain at one facility, the Baylor model requires students to complete six separate threemonth rotations at different types of facilities, increasing their exposure to a variety of settings. “We hand-select some of the best facilities” to serve as residency sites, explains Howell. The sites must be accredited by NCOPE and must agree to uphold Baylor’s standard in working with residents; the sites must agree to “teach” part of the curriculum to the residents. Residents are tested at the end of each rotation. Howell believes this model benefits the students—who will come away with a diverse array of experiences in both orthotics and prosthetics—as well as the residency sites, since the model “opens up opportunities for some facilities to host residents.” Howell emphasizes that Baylor has been careful about which facilities it has selected to be included in the program. “You have to be willing to invest in people’s future,” to be considered, he says. Baylor has accepted local facilities as well as facilities located across the country as residency sites, as some students are open to traveling. Seabrook notes that this new residency model is distinct in that “you pull out the notion that you are an employee of the physician.” This new model keeps the residency as purely educational since it is unpaid. This could be an incentive for more facilities to choose to become NCOPEaccredited residency sites. While Seabrook acknowledges that the Baylor model may not work
“Evolutions in patient care, research, and education could not have happened if it was not for the efforts of many individuals, and hopefully the next generation will continue to [move] forward. The students of today are the mentors of tomorrow.” —Chris Robinson, CPO, MBS, MS, ATC, FAAOP
at all schools, she notes that some schools could explore a hybrid model— something in between the traditional approach and the Baylor model. “And there could be other models out there,” says Seabrook. “Going forward, we will need to look at more outsidethe-box models” to prepare the next generation of O&P practitioners for the future of the industry.
A More Diversified O&P Care Team In addition to more highly trained certified practitioners, the O&P profession of the future will see an increasing number of staff members trained in specific aspects of O&P care. “O&P has changed dramatically over the last 10 years in terms of extenders of care,” explains Seabrook. “There used to be just the practitioner level and the technician level. Now there are a lot more extenders of care,” including assistants, orthotic fitters, pedorthists, and mastectomy fitters. As more individuals seek training as technicians or specifically trained care providers, the profession will evolve to best fit all of the pieces of the O&P care puzzle together—and integrate those pieces to benefit patients. The idea is to ensure that certified practitioners serve as the managers of patient care, while extenders of care complete some
of tasks that do not necessarily need to be performed by a certified practitioner, says Seabrook. This model continues to gain in popularity as practitioners seek to improve profitability even as they spend more time on documentation issues and writing letters to Medicare and third-party payers.
Future Steps As the need for O&P care grows, the need for qualified practitioners will grow—and it’s a positive sign that today’s educators are incorporating a forward-thinking viewpoint into their training strategies. Putting it all into context, Robinson says: “It is important to understand the challenges and triumphs that the profession of orthotics and prosthetics has faced over its relatively short existence. Experienced clinicians have not only fought for the O&P profession of today, but also its future. Evolutions in patient care, research, and education could not have happened if it was not for the efforts of many individuals, and hopefully the next generation will continue to [move] forward. The students of today are the mentors of tomorrow.” A Christine Umbrell is a contributing writer to O&P Almanac. Reach her at email@example.com. JANUARY 2014 O&P Almanac
By Devon Bernard, AOPA government affairs department
Updating HIPAA Policies and Procedures
New regulations and updates every facility must know about in 2014
n January 2013, modifications to the Health Insurance Portability and Accountability Act (HIPAA) Privacy, Security, Enforcement, and Breach Notification Rules under the Health Information Technology for Economic and Clinical Health (HITECH) Act and the Genetic Information Nondiscrimination Act (GINA) were announced; and the HIPAA Omnibus Rule, or final rule, was released—all with a mandatory compliance date of Sept. 23, 2013. The final rule is based on and modifies provisions that were first enacted under the HITECH Act in 2010. Many of the Omnibus Rule changes are not new and shouldn’t have been a big surprise. However, there were enough changes that O&P facilities should have updated their HIPAA policies and procedures.
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To be considered compliant with the Omnibus Rule, you should already have updated your Notice of Privacy Practices (NPP) and created a policy that allows you to indentify breaches of patient’s information and a policy of how to handle breaches. You also should have amended or be in the process of amending your current business associate agreements or entering into new agreements with your business associates. If you have not made these changes yet, be sure you begin the process now. It’s not too late to limit your exposure and culpability. This inaugural Compliance Corner column will focus on the items that had a compliance date of Sept. 23, 2013, and help make sure you are still compliant or on the path to becoming compliant.
Breach Notification Policy You are required to notify patients when a breach of their protected health information (PHI) has occurred. First, review your policies and procedures and determine if they allow you to identify and respond to any suspected or known breaches. Second, determine if your policy and procedures accurately outline how you will notify patients of a breach. For these purposes, a breach means the acquisition, access, use, or disclosure of protected health information in a manner not permitted under the HIPAA Privacy Rule that compromises the security or privacy of the PHI. However, the Omnibus Rule states that the acquisition, access, use, or disclosure of protected health information in a manner not permitted under the HIPAA Privacy Rule is presumed to be a breach unless the covered entity can show/demonstrate that there is a low probability that the PHI in question has been compromised. A risk analysis can help you determine whether or not this has occurred. The Omnibus Rule provides you with four factors that must be part of your risk analysis, though you may use additional factors if you choose. First, appoint an individual, perhaps your current HIPAA Privacy Officer, to be responsible for conducting the investigation and ensuring results are fact-based and well-documented. The following four factors must be present in your policy and procedure manual:
• Examine the unauthorized person who used the PHI or to whom the disclosure was made. Was it an employee or a third party? Is the person trustworthy? Is the person/ entity required to follow HIPAA? • Determine if the PHI was actually acquired/viewed. Was the information encrypted? Was the security seal broken? • Evaluate the type and amount of information that was accessed, used, or disclosed and the nature and the extent of the PHI. Is it sensitive information, like social security numbers? What type of information was disclosed and used? • Establish the extent to which the risk to the PHI has been mitigated. Were there corrective steps taken to stop future/further disclosures? Was there something that could have been done to mitigate the improper disclosure?
Notifying Patients of a Breach The final component of what should—at minimum—be part of your breach policies and procedures is how to notify the patients effected by the breach. Notification to the affected individuals must be done without delay and no later than 60 days after discovery of the breach. Notifications should be written in a plain language and mailed to the individuals address and should include the following information: • a brief description of the breach, including a description of the types of PHI involved • a brief description of any steps that you are taking to mitigate the potential harmful effects of the breach • an explanation of any steps that individual can take to protect them from potential harm resulting from the breach • contact information for individuals to obtain additional information about the breach. Additionally, if more than 500 individuals were affected by the breach,
you should notify the Secretary of Health and Human Services (HHS), as well as prominent media outlets, when you notify the affected individuals. A log of all breaches should be maintained and submitted to the Secretary of HHS no later than 60 days after the end of each calendar year. Also consider what steps you can take to mitigate the possible damage of a breach, what sanctions can result from allowing a breach to occur, what training should be done to educate employees about the breach policies, and more.
The Omnibus Rule granted patients additional rights, protection, and control in how their PHI can be used, disclosed, or accessed. Notice of Privacy Practices (NPP) The Omnibus Rule granted patients additional rights, protection, and control in how their PHI can be used, disclosed, or accessed. For example, the sale of PHI for any reason or purpose is prohibited unless the patient provides direct authorization. Patients also have the right to request a copy of their PHI in any form they choose, and you must provide a copy within 30 days. Your NPP must be updated to reflect these changes and must be made available to all patients. According to the final rule, NPPs must include:
• information on your obligation to notify patients when a breach of their PHI occurs • a statement indicating the patient’s right to request that a health plan not be informed of treatment that is paid for in full by the patient and that you must comply with this request • a statement indicating that authorization is required for uses and disclosures of PHI for marketing purposes and disclosures that constitute a sale of PHI • a statement indicating that if you maintain psychotherapy notes, you must receive authorization for most uses and disclosures of the psychotherapy notes • a statement providing patients with the right to opt out of receiving communications in regards to fundraising activities • a statement noting that other uses and disclosures not described in the NPP will only be made with authorization from the patient • a statement noting that a health plan is prohibited from disclosing genetic information for underwriting purposes. Not all of these will apply to every practice, so be sure to examine your business practices carefully and remove any items that don’t apply to you. If you updated your NPP, be sure your policies and procedures are up-todate as well. For example, your current policy that outlines a patient’s rights to authorize/restrict disclosures of his or her PHI will have to be updated to show that you must comply with the patient’s request not to disclose his or her PHI to the patient’s health plan if the service is paid for out of pocket and in full. a Devon Bernard is assistant director of coding reimbursement, programming, and education for AOPA. Reach him at dbernard@ AOPAnet.org.
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Facility Spotlight By Deborah Conn
SRT’s National Prosthetic Center in Indiana.
Treating the ‘Whole Patient’
A growing facility offers a number of programs to support amputees both inside and outside of the clinic
Sam Santa-Rita, CP, LP, with a patient.
Facility: SRT Prosthetics & Orthotics Location: Headquarters in Bryan, Ohio, with 7 offices in Ohio and Indiana Owner: Sam Santa-Rita, CP, LP History: 12 years in business
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am Santa-Rita’s first exposure to the O&P field came when he was 12 years old and traded in his paper route to help out at an O&P facility in Toledo, Ohio, owned by Gary Fessenden. Santa-Rita started by mowing the lawn and progressed to his “first real job in O&P,” running a sewing machine. Fast forward to 2001, when, after becoming a certified prosthetist and working for both Wright & Filippis and Hanger, Santa-Rita decided to open his own practice. He began building a facility in Fort Wayne, Indiana, that was soon followed by locations in Kokomo and Bryan, Ohio. Today, SRT Prosthetics & Orthotics has seven offices in Ohio and Indiana, including the National Prosthetic Center in Indianapolis, a 14,000-square-foot facility offering patients real-world scenarios to test their prostheses, a fully equipped gym, and a room devoted to activities of daily living.
SRT has 38 employees, including 12 clinicians. The company handles all of its own fabrication in two facilities, one in Fort Wayne that serves the northern parts of Ohio and Indiana, and one in Indianapolis that supports the remainder of the state. SRT focuses on both lower- and upper-extremity prosthetics, which accounts for about 90 percent of its patients. “We do
Patients at SRT’s Amputee Walking School.
orthotics as well,” says Santa-Rita, “but prosthetics is my passion.” SRT offers a full range of devices, including those for elite athletes and others using highly advanced technologies. In addition to its daily O&P services, SRT features a number of programs to benefit amputees. The Amputee Walking School is a joint project with former Paralympic gold medalists Dennis Oehler and Todd Schaffhauser, who have designed a community program bringing together amputees for strength-training exercises, socializing, and support.
SRT patients enjoying their hobbies.
started to realize that more than half of my patients, especially in Detroit, carry firearms,” he says. “I felt it was important for them to know how to prevent threatening situations, or to handle them responsibly and effectively.” Santa-Rita and TDI collaborated on a program specifically for amputees and others with physical challenges. SRT also sponsors The Way Outfitters, an organization that offers outdoor experiences to those with disabilities, including hunting, fishing, deep sea diving, and horseback riding. The group is the subject of a nationally aired television show on the Sportsman Channel that follows participants on their adventures. SRT is sole sponsor of the show, which has featured patients in several episodes. Santa-Rita believes the O&P industry is facing tough times ahead in the face of RAC audits. “We struggled with cash flow for a year, and it took some painful changes, but I’m happy
to say we have turned the corner,” he says. “Unfortunately, some excellent clinicians are not necessarily savvy business people, and I think we’ll be seeing a lot of facilities that can’t improve their productivity having to close.” Responding to RAC audits was a learning experience, Santa-Rita says, and SRT is winning most audits now. “We run a very transparent business,” he says. Although Santa-Rita is waiting to see how the Affordable Care Act will affect his business, he already has identified facilities and geographical areas for future expansion. No matter how big SRT becomes, however, he stresses that his company’s mission will remain the same: to focus on the whole person, not just the part that is missing. a Deborah Conn is a contributing writer to O&P Almanac. Reach her at debconn@ cox.net. JANUARY 2014 O&P Almanac
Photos: SRT Prosthetics & Orthotics
“Amputees find a light, positive atmosphere at the Walking School,” explains Santa-Rita. “There are nicknames, hugs, friendly teasing. It also gives physical therapists (PTs) and occupational therapists (OTs) the chance to have a hands-on experience with amputees and for prosthetists to see how their devices are working in the real world.” In conjunction with the Walking School, SRT offers a half-day training for PTs and OTs in working with amputees. The training is free and recently qualified as a source of continuing education credits for therapists. The company also offers formal educational programs at PT and OT facilities, including nursing homes, outpatient therapy groups, and hospitals. These, too, provide continuing education credits and are free of charge. Santa-Rita has another passion: selfdefense. He qualified as a police officer in Ohio in 2009, attending school at night, and became an instructor with the Tactical Defense Institute (TDI), which offers self-defense and firearm training. Santa-Rita said he learned early on that amputees can have a heightened concern for their personal safety. “I
AOPA WORKING FOR YOU
Pulling Out All the Stops Making strides with O&P’s 2014 legislative agenda
ast January, we reported the exciting news that the 2.3 percent medical device tax exemption secured by AOPA would save O&P patients, patient-care facilities, and suppliers a whopping $95 million a year. It was a wonderful example of how a national trade association can truly deliver a dollarsand-cents value to members. We only wish we had a similar good news story as the year begins. Questions abound about how the Affordable Care Act will affect O&P providers and patients. There continues to be brinkmanship politics in Washington with few if any changes expected soon. The 2014 November elections may provide some resolution but experience suggests we shouldn’t count on it. Still, there are some encouraging prospects for O&P. The lawsuit against the Centers for Medicare and Medicaid Services (CMS) triggered by the unfair Recovery Audit Contractor audits is still winding its way through the legal system and if it surpasses the next hurdle, namely the government’s motion to dismiss, there will be a greater chance that it will provide relief. Most lawsuits against CMS and the government usually fail at that early stage of action, so if AOPA’s suit is able to beat the odds, there is cause for optimism that relief from onerous audits may be in the offing. The Medicare O&P Improvements Act, HR 3112, has continued to garner support with eight bi-partisan cosponsors joining with Representatives Glenn Thompson (R-Pennsylvania) and Mike Thompson (D-California) to support the bill. Co-sponsors include: Representatives Tammy Duckworth (D-Illinois), Tim Griffin (R-Arkansas), Brett Guthrie (R-Kentucky), Peter King (R-New York), Tom Latham (R-Iowa), Peter Roskam
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(R-Illinois), C.A. Dutch Ruppersberger (D-Maryland), and Aaron Schock (R-Illinois). AOPA is working with several prospective sponsors and co-sponsors to have a companion bill introduced on the Senate side. Both the Senate and House of Representatives had similar legislation pending in the last Congress. HR 3112 would prohibit CMS from making any payment for orthotics and prosthetics to a provider who is not appropriately licensed in a state requiring licensure. Second, the bill will require practitioners in states without licensure requirements to be accredited. The combination of these two much-needed reforms will keep fraudulent providers out of the O&P arena, so that only legitimate, qualified providers will be paid for serving O&P Medicare beneficiaries.
Tom Kirk speaks with Representative Tammy Duckworth (D-Illinois).
Since eligibility for payment will be linked to the qualifications of the providers and the complexity of the device the patient needs, quality of patient care will be improved. Additionally, taxpayer dollars will be saved through a reduction in poor outcomes and repeated charges for follow-up O&P care that would not be necessary if a qualified provider served the patient in the first instance.
AOPA WORKING FOR YOU Boosting O&P Education, Research Progress also is being made on two bills dealing with O&P research and education introduced by Senator Dick Durbin (D-Illinois), S 521 and S 522—both a result of efforts by AOPA’s consultant, Linchpin Strategies. The Wounded Warrior Research Enhancement Act (S 521) provides $30 million in research funds, which, among other objectives, will develop an agenda for the most important unanswered questions in O&P evidence-based clinical care. The Wounded Warrior Workforce Enhancement Act (S 522) will award no less than $1 million and no more than $1.5 million, for a total of $15 million in grants to eligible institutions to establish or expand a master’s degree or doctoral program in orthotics and prosthetics. The money may be used to supplement faculty salaries and offer financial aid to admit additional students and a host of other positive actions to enhance O&P teaching institution programs. The bill also provides $5 million in grant money to establish a Center for Excellence in Orthotic and Prosthetic Education. Underscoring the importance of this legislation are the provisions requiring the Veterans Administration, the Department of Defense, and the O&P community to collaborate in setting the research agenda and identify topics for grants that would respond to the most important unanswered questions in clinical care. Working with the Amputee Coalition, AOPA has led the effort resulting in the Insurance Fairness for Amputees Act (HR 3020), which was introduced by Representative Charles Dent (R-Pennsylvania) and co-sponsored by Representative Rob Andrews (D-New Jersey). HR 3020 would require insurers that offer O&P benefits to provide the same benefits as those offered for other surgical and medical coverage provided in the policy with no caps or lifetime limits. There was similar legislation in both the Senate and House in the previous Congress.
600 contracts with private O&P practitioners) • a second opinion from VA medical personnel as to O&P treatment options • access to a functional spare prosthetic limb or orthotic brace • timely and efficient prosthetic and orthotic care.
The Wounded Warrior Research Enhancement Act (S 521) provides $30 million in research funds, which, among other objectives, will develop an agenda for the most important unanswered questions in O&P evidencebased clinical care.
Representative Renee Ellmers (R-North Carolina) introduced the Injured and Amputee Veterans Bill of Rights (HR 3408) on Oct. 31, 2013, following strong advocacy by National Association for the Advancement of Orthotics & Prosthetics. This bill will require the U.S. Department of Veterans Affairs (VA) to post a written list of “rights” that apply to every veteran in need of prosthetic limb and orthotic care. While veterans currently have these rights, many veterans and even VA employees are unaware of the available health-care options. The rights provided by HR 3408 include: • access to appropriate O&P technology to meet individual veterans’ needs • ability to receive care from a private O&P practitioner of choice (the vast majority of veterans receive prosthetic care through
This legislation is a bipartisan measure to ensure that veterans with injuries and amputations obtain appropriate O&P care. Inconsistency in care across the country is a problem, and this bill moves to create consistent and patient-centered health care. Support for these five bills will be on the 2014 Policy Forum “ask list” as AOPA members gather once again in the ongoing effort to educate legislators and their staff about the unique and positive impact O&P care has on patient outcomes—and most importantly, the expenditures by Medicare and other payers. The AOPA-funded research project commissioned by the Amputee Coalition using Medicare data tracked expenses associated with two cohorts of patients with the same diagnoses and found timely O&P invention provides more cost-effective outcomes for those who received O&P care versus those who did not. Dates for the AOPA Policy Forum cannot be set until Congress reconvenes and sets its calendar; otherwise, there remains a high risk of selecting a date when members of Congress are back home campaigning for re-election. As soon as the dates are available, AOPA will use multiple communication tools to make sure AOPA members mark their calendars to join the annual education effort. But you don’t have to wait for the Policy Forum to contact your legislator and urge his or her support and co-sponsorship of each of these bills that are so important to O&P patients and providers. You can access “ready to go” letters that can be customized for each of these bills from the “Regulatory and Legislative” pull-down menu at www.AOPAnet.org. a
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AOPA Reaffirms Support for the Convention on the Rights for Persons With Disabilities AOPA’s Aug. 6, 2013, letter to Senate Majority Leader Harry Reid (D-Nevada) and Senate Minority Leader Senator Mitch McConnell (R-Kentucky) signaled AOPA’s support for the Convention on the Rights for Persons with Disabilities (CRPD) as a continued effort to show U.S. world leadership in enhancing the rights of persons with disabilities “by asserting that persons with disabilities have the same rights as persons without disabilities.” The U.S. Senate is once again poised to consider this landmark legislation, and AOPA members are urged to contact their senators requesting support. In the letter to the Senate leadership, AOPA pointed out that the U.S. Chamber of Commerce, the U.S. Business
Leadership Network, and the Information Technology Council are among the many leading organizations that support ratification of CRPD. AOPA and the O&P community know that what’s good for O&P patients and others with disabilities is ultimately good for the country. Ask your senator to ratify the CRPD. You can use AOPA’s letter as a guide to create your own message urging support; visit www.aopanet.org/EndorsementLetterCRPD.pdf.
New Year, New Opportunity: Are You Billing for All That You Can? Join the Audio Conference January 8 Are you billing for all that you can? New codes and modifier changes are effective Jan. 1, 2014. Do you have a plan in place? As we welcome a new year, join AOPA January 8 for an AOPAversity Mastering Medicare Audio Conference that will focus on billing opportunities that you may have overlooked, and will explain why this is an important part of your business operation. An AOPA expert will address how to bill for the following: • Deluxe or upgraded features • Refused or returned items • Patient evaluations • Miscellaneous codes • Repairs and adjustments. AOPA members pay just $99 ($199 for nonmembers), and any number of employees may listen on a given line. Participants can earn 1.5 continuing education credits by returning the provided quiz within 30 days and scoring at least 80 percent. Contact Devon Bernard at dbernard@ AOPAnet.org or 571/431-0854 with content questions. Register online at http://bit.ly/aopa2014audio. Contact Betty Leppin at bleppin@AOPAnet.org or 571/431-0876 with registration questions.
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Billing for Diabetic and Orthopedic Shoes, Mastectomy Services, and Surgical Dressings Join the Audio Conference February 12 Having a hard time billing properly for shoes, dressings, and external prostheses? Join AOPA February 12 for an AOPAversity Mastering Medicare Audio Conference that will focus on Medicare policies and correct billing opportunities for diabetic and orthopedic shoes, mastectomy services, and surgical dressings. The following topics will be covered: • How to bill for split shoe sizes • How to bill for diabetic shoes attached to braces • How many bras may be dispensed at one time • How and when compression garments are considered medically necessary.
Coming Soon 2014 AOPA Product Directory AOPA’s mission is to work for favorable treatment of O&P business in laws, regulations, and services to help members improve their management and marketing skills, and to raise awareness and understanding of the industry and the association. AOPA is proud to announce the 2014 Product Directory is coming soon—visit www.aopanet.org.
AOPA members pay just $99 ($199 for nonmembers), and any number of employees may listen on a given line. Participants can earn 1.5 continuing education credits by returning the provided quiz within 30 days and scoring at least 80 percent. Contact Devon Bernard at dbernard@ AOPAnet.org or 571/431-0854 with content questions. Register online at http://bit.ly/aopa2014audio. Contact Betty Leppin at bleppin@AOPAnet.org or 571/431-0876 with registration questions.
If You’re Paying More Than 1.9%, You’re Paying Too Much AOPA has partnered with Bank of America Merchant Services to offer credit card processing rates as low as 1.9 percent to AOPA members. Many members are paying more than 2.5 percent, and if you’re handling $500,000 a year in credit card transactions, the 0.6 percent savings is like getting a 200 percent return on your membership dues investment. To enroll, contact 888/317-5402 or email firstname.lastname@example.org. AOPA encourages members to request an audit of a recent processing statement to identify the savings they would enjoy.
Coding Questions Answered 24/7 AOPA members can take advantage of a “click-of-the-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.
24/7 JANUARY 2014 O&P Almanac
New Business Education Programs for 21st Century Entrepreneurs:
Survive and Thrive— Bottom-line, profitoriented business programs for O&P If you missed the 2013 O&P World Congress, don’t let this opportunity to participate in these important programs pass you by: • Everything You Need to Know to Survive RAC and Prepayment Audits in a Desperate Environment • Competitive Bidding: Devastation to Orthotic Patient Care, Or Just a Passing Storm? • Food and Drug Administration Compliance for Patient-Care Facilities, Manufacturers, and Distributors • Your Mock Audit: Are You Ready for the Auditor to Examine Your Claims Record? You and your staff can now have a private viewing of business saving strategies and BUY 3 earn CE credits at the same time. Learn more about each session by visiting www.aopanet. org/Need%20CE%20Credits%20Promo.pdf. AOPA members just $59 per session ($99 per session for nonmembers), and the price covers your entire staff. Take advantage of a special offer to buy three, get one free. Review the videos as many times as you like. Register at http://bit.ly/aopabusiness. Contact Betty Leppin at bleppin@AOPAnet.org or 571/431-0876 with any questions.
‘2013 Operating Performance Report’ & ‘2013 Compensation & Benefits Report’ Are you curious about how your business compares to others? These updated surveys will help you see the big picture. AOPA’s “2013 Operating Performance Report” provides a comprehensive financial profile of the O&P industry including balance sheet, income statement, and payer information organized by total revenue size, community size, and profitability. The data was submitted by 98 patient-care companies representing 1,011 full-time facilities and 62 part-time facilities. This report provides financial performance results as well as general industry statistics. Except where noted, all information pertains to fiscal year 2012 operations. AOPA’s “2013 Compensation & Benefits Report” represents the most complete, accurate, and up-to-date compensation information for the O&P industry. This report is designed to allow industry members to easily compare their compensation levels and benefits policies with those of similar facilities. The report is divided into two major sections: average salaries and ranges of key employee positions, and benefits offered, including holiday and vacation policies. Both reports may be purchased in the AOPA Bookstore at www.aopanetonline.org/store.
O&P Almanac Magazine—Don’t Miss an Issue! If you aren’t receiving and reading AOPA’s official magazine every month, you don’t know what you’re missing. The O&P Almanac is the most respected source for industry insight and association news in the O&P industry. Featured topics include emerging technologies, coding and reimbursement education, premier meetings, people and businesses in the news, and industry modernization. As a member of AOPA, or a credentialed practitioner with ABC or BOC, you receive a print copy of the O&P Almanac monthly. Your print issue features all of the latest O&P news, regular departments, and special features on
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hot topics. A digital version of each issue also is available on AOPA’s website at www.aopanet.org under “Publications.” If you are not a member of AOPA, or a credentialed practitioner with ABC or BOC, you may purchase an annual subscription of the O&P Almanac at AOPA’s Online Bookstore, www.aopanetonline.org/store.
Mastering Medicare: AOPA’s Advanced Coding & Billing Techniques Royal Sonesta | Feb. 9-10, 2013 New Orleans, LA Join your colleagues February 9-10 at the Royal Sonesta in New Orleans for AOPA’s Mastering Medicare: Advanced Coding & Billing Techniques seminar. AOPA experts will provide up-to-date information to help O&P practitioners and office billing staff learn how to code complex devices, including repairs and adjustments, through interactive discussions and much more. Meant for both practitioners and office staff, this advanced two-day event will feature breakout sessions for these two groups to ensure concentration on material appropriate to each group. Basic material that was contained in AOPA’s previous Coding & Billing seminars has been converted into nine one-hour webcasts. Register for the webcasts on AOPA’s homepage.
Register online for the Mastering Medicare: Advanced Coding & Billing Techniques seminar in New Orleans at http://bit.ly/aopa2014neworleans. Questions? Contact Devon Bernard at dbernard@aopanet. org or 571/431-0854.
RH Media Takes Over O&P Almanac Advertising Sales RH Media, LLC assumed advertising sales responsibilities for the O&P Almanac on Dec. 1, 2013. Bob Heiman, owner of RH Media, will be the key contact for growing the magazine’s advertising reach and value to the orthotic and prosthetic community. AOPA’s Executive Director Tom Fise welcomed Mr. Heiman to the AOPA team saying, “Bob has been a professional in the health-care field since 1978, gaining experience in various health-care marketing positions as a medicalmedia researcher, ad agency media director and account executive, and, beginning in 1984, advertising space sales, before launching his own ad rep agency, RH Media, in 2005. He has continued to build an expanding ad presence for his stable of publications and we look forward to his continuing record of success in his new responsibilities with the O&P Almanac.”
Heiman’s experience goes across the entire health-care continuum of product and service suppliers: pharmaceutical, diagnostic, IT, formulary, managed care, equipment, and more. Additionally, he has worked closely with societies in generating revenues through special projects. Contact Bob Heiman by email at email@example.com or by phone, 856/673-4000, for special pricing on bi-annual display advertising opportunities and the new multimedia offerings. JANUARY 2014 O&P Almanac
Save the Dates: 2014 AOPA Audio Conferences Announced Mark your calendar now for the audio conferences in 2014. AOPA has confirmed the dates and topics for its 2014 series of audio conferences. Educate yourself and your staff during one-hour sessions in the comfort of your office on the second Wednesday of each month at 1:00 p.m. EDT. This series provides an outstanding opportunity for you and your staff to stay abreast of the latest hot topics in O&P, as well as gain clarification and ask questions.
Buy the Series and Get Two FREE! Visit the AOPA website, buy the series, and get two audio conferences free. AOPA members pay $990 to participate in all 12 sessions (nonmembers pay $1,990). If you purchase the entire year’s worth of conferences, all conferences from the months prior to your purchase of the set will be sent to you in the form of an MP3. Individual seminars are priced at just $99 per line for members ($199 for nonmembers).
Register online at http://bit.ly/aopa2014audio. Questions? Contact Betty Leppin at bleppin@AOPAnet.org or 571/431-0876.
2014 Topics • January 8: New Year, New Opportunity: Are You Billing for All That You Can? • February 12: Billing for Diabetic and Orthopedic Shoes, Mastectomy Services, and Surgical Dressings • March 12: The ABCs of Audits: What to Expect and How to Respond • April 9: How To Use Advanced Beneficiary Notices (ABNs) Effectively • May 14: Modifiers: How and When to Use Them • June 11: The Self-Audit: A Useful Tool • July 9: The OIG: Who Are They and Why Are They Important? • August 13: AFO/KAFO Policy: Understanding the Rules • September 10: Urban Legends in O&P: What To Believe • October 8: Medicare Enrollment, Revalidation, and Participation • November 12: Gifts: Showing Appreciation Without Violating the Law • December 10: New Codes and Changes for 2015
Follow AOPA on Facebook and Twitter Follow AOPA on Facebook and Twitter to keep on top of latest trends and topics in the O&P community. Signal your commitment to quality, accessibility, and accountability, and strengthen your association with AOPA, by helping build these online communities. Like us on Facebook at: www.facebook. com/AmericanOandP with your personal account and your organization’s account! Follow us on twitter: @americanoandp, and we’ll follow you, too! Contact Steve Custer at scuster@AOPAnet.org or 571/4310835 with social media and content questions.
Top 5 Reasons To Follow AOPA: • Be the first to find out about training opportunities, jobs, and news from the field. • Build relationships with others working in the O&P field. •
Stay in touch with the latest research, legislative issues, guides, blogs, and articles—all of the hot topics in the community.
• Hear from thought leaders and experts. • Take advantage of special social media follower discounts, perks, and giveaways.
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Log On to AOPAversity Online Meeting Place for Free Education does not get any more convenient than this. Busy professionals need options––and web-based learning offers sound benefits, including 24/7 access to materials, savings on travel expenses, and reduced fees. Learn at your own pace—where and when it is convenient for you. For a limited time, AOPA members can learn and earn for FREE at the new AOPAversity Online Meeting Place: www.AOPAnetonline.org/education. Take advantage of the free introductory offer to learn about a variety of clinical and business topics by viewing educational videos from the prior year’s National Assembly. Earn CE credits by completing the accompanying quiz in the CE Credit Presentations Category. Credits will be recorded by ABC and BOC on a quarterly basis.
AOPA also offers two sets of webcasts: Mastering Medicare and Practice Management. • Mastering Medicare: Coding & Billing Basics: These courses are designed for practitioners and office staff who need basic to intermediate education on coding and billing Medicare. • Practice Management: Getting Started Series: These courses are designed for those establishing a new O&P practice. Register online by visiting http://bit.ly/AOPAwebcasts.
AMERICAN ORTHOTIC & PROSTHETIC ASSOCIATION
Business Optimization Analysis Tool (BOAT) AOPA’s largest and most successful members use the BOAT. The BOAT will help you:
Provide access to the new AOPA Patient Satisfaction Survey (required by certifying bodies).
Participate in the annual Operating Performance and Compensation survey (OPC) —which provides you with a personal benchmark comparison study.
You will have access to your own secure and confidential account on the BOAT which will contain your company’s reported data and is specifically tailored to help O&P
OPC data you submit will automatically populate your BOAT site providing valuable historical information
This Amazing Profit Booster is FREE for AOPA Members.
understand your competi-
financial fitness of your business
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
tion, market conditions and referral sources
And much more!
JANUARY 2014 O&P Almanac
to the 2013* O&P PAC Contributors AOPA would like to thank the following individuals for their contributions in 2013 to the O&P PAC:
Chairman’s Table ($100-$499)
President’s Circle ($1,000-$5,000)
Senator’s Table ($500-$999)
Sherrie Anderson, CP
Frank Bostock, CPO
Kel Bergmann, CPO
Charles Dankmeyer, CPO
Ted Drygas, CPO
J. Martin Carlson, CPO Thomas DiBello, CO, FAAOP Mike Fenner, CP, BOCPO Thomas F. Fise, JD Rick Fleetwood, MPA Richard Gingras, CPO, BOCOP David Kerr Thomas Kirk, PhD Jon Leimkuehler, CPO, FAAOP
Ronald Hercules Alfred Kritter, CPO, FAAOP William Leimkuehler, CPO, FAAOP Ronald Manganiello Michael Oros, CPO Rodney Pang, CPO Ronald Pawlowski, CPO John Roberts Jr., CPO Lisa Schoonmaker, CPO, FAAOP Jack Steele
Mark Maguire, CPO
Frank Vero, CPO
James Weber, MBA
Walter Racette, CPO
Bradley Ruhl Scott Schneider Rick Stapleton, CPO Gordon Stevens, CPO Paulette Vaughn Bernie Veldman, CO Thomas Watson, CP James Young Jr., CP, FAAOP
O&P Almanac JANUARY 2014
George Breece Alan Burke Michael Burton Erin Cammaratta Jim Campbell, CO, FAAOP, PhD James Claiborne Thomas Colburn, CO, C.Ped, FAAOP Jeff Collins, CPA Kenneth Cornell, CO A.J. Filippis, CPO Jim Fitzpatrick Mark Hopkins, PT, CPO Joseph Huntsman Jim Kingsley Thomas LeTourneau, PhD, CPO, FAAOP Eileen Levis Robert Maniere, CPO, C.Ped, FAAOP Michael Martin, CO, FAAOP Clyde Massey, CPO Brad Mattear, CPA, Cfo Kevin Matthews, CO Steve McNamee, CP, BOCO, FAAOP Steven Mirones, CO, FAAOP Gaurav Mishra Jonathan Naft, CPO Josep Ramicone, CPO Eric Ramos Ricardo Ramos, CP, C.Ped Walt Raynor Eduardo Reyes, CPO Stephen Rinko, CPO Michael Schlesinger Donald Shurr, CPO, PT Jeffrey Smith, CPO William Snell, CPO Peter Thomas, Esq. Jeff Wensman, CPO Claudia Zacharias, MBA, CAE
1917 Club (Up to $99)
2013 PAC Supporters
These individuals have generously contributed directly to a political candidateâ€™s fundraiser and/or have donated to an O&P PAC sponsored event.
Ed Bannister Paul Boland, CPO Zachary Coker Bill Cornell Christina Cox Charlie Eaton Micha Gaspar, CO Cindy Henderson Michelle Henslee, CO Joe Jesson Reggie Jones, BOCO, CO
Robert Arbogast Ryan Arbogast Kel Bergmann, CPO Frank Bostock, CO Brightree, LLC Alan Burke Jim Campbell, CO, FAAOP, PhD Maynard Carkhuff Kevin Carroll, CP, FAAOP Dennis Clark, CPO Thomas Colburn, CO, C.Ped, FAAOP Jeff Collins, CPA
Timothy Lacy, CP Anita Liberman-Lampear, MA Mohamad Mansoori, CP Sean McKale, CO Robin Merriam John Mooney, CPO Kristen Smith Christian Smith Laurel Voss, BOCPO Paul Werner, CPO Jaisen Westbrook Dennis Wood, CTP Mike Wright, CP
Special Thanks The purpose of the O&P PAC is to advocate for legislative or political interests at the federal level that have an impact on the orthotic and prosthetic community. The O&P PAC achieves this goal by working closely with members of the House and Senate to educate them about O&P issues and to help elect those individuals who support the O&P community. To participate in the O&P PAC, federal law mandates that you must first sign an authorization from. To obtain an authorization form, contact Devon Bernard at firstname.lastname@example.org.
Thomas Costin Glenn Crumpton, CPO Charles Dankmeyer, CPO Don DeBolt Thomas DiBello, CO, FAAOP Susan Diekrager Kim Doolan ExpoTrac Mike Fenner, CP, BOCPO James Fenton, CPO Ray Fikes, CPO Rick Fleetwood, MPA Arlene Gillis Richard Gingras, CPO, BOCOP Tom Guth Michael Hamontree Hanger PAC Matthew Hayden Jason Jennings, CP James Kaiser, CP Marc Karn, CP Thomas Kirk, PhD Alfred Kritter, CPO, FAAOP
Timothy Lacy, CP William Leimkuehler, CPO Jon Leimkuehler, CPO, FAAOP Eileen Levis Anita Liberman-Lampear, MA Pam Lupo, CO Ronald Manganiello Joe McTernan Tina Moran, CPM Michael Oros, CPO Stan Patterson PPSV PAC PROTEOR Paul Prusakowski, CPO Bradley Ruhl Scott Schneider William Snell, CPO Frank Snell, CPO, FAAOP Terry Supan, CPO, FAAOP Peter Thomas, Esq. Frank Vero, CPO Thomas Watson, CP James Weber, MBA Eddie White, CP James Young Jr., CP, FAAOP Claudia Zacharias, MBA, CAE
*Due to publishing deadlines, this list was created on Dec. 4, 2013, and includes only donations received between Jan. 1, 2013, and Dec. 4, 2013. Any donations received on or made after Dec. 4, 2013, will be published in the next issue of O&P Almanac.
JANUARY 2014 O&P Almanac
Welcome new members! The officers and directors of the American Orthotic & Prosthetic Association (AOPA) are pleased to present these applicants for membership. Each company will become an official member of AOPA if, within 30 days of publication, no objections are made regarding the companyâ€™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 statelicensed practitioner who qualifies that patient-care facility for membership according to AOPAâ€™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.
Capital Prosthetics & Orthotics 1455 Harden Street Ext. Columbia, SC 29202-1755 803/799-5063 Fax: 803/252-0872 Category: Affiliate Member Parent Company: Carolina Orthotics & Prosthetics Inc., N. Charleston, SC
Center for Orthotic & Prosthetic Care 125 N. Weinbach Avenue, Ste. 310 Evansville, IN 47711 812/479-6298 Fax: 812/479-6758 Category: Affiliate Member Parent Company: Center for Orthotic & Prosthetic Care, Louisville, KY
Center for Orthotic & Prosthetic Care 522 Liberty Street Syracuse, NY 13204 315/218-6706 Fax: 315/314-7652 Category: Affiliate Member Parent Company: Center for Orthotic & Prosthetic Care, Louisville, KY 42
O&P Almanac JANUARY 2014
Fourroux Prosthetics 2845 N. Houston Levee Road, Ste. 103 Cordova, TN 38016 901/383-1827 Fax: 901/383-1829 Category: Affiliate Member Parent Company: Fourroux Prosthetics Inc., Huntsville, AL
LIM Innovations 926 Howard Street San Francisco, CA 94103 415/568-7730 Category: Institute Member Garrett Hurley
Louisville Prosthetics 1404 Browns Lane, Ste. C Louisville, KY 40207 502/895-8050 Fax: 502/895-8056 Category: Affiliate Member Parent Company: Louisville Prosthetics, Louisville, KY
MJ Walk/dba Carolina-Walk Orthotics and Prosthetics 300 New River Parkway, Ste. 12 Hardeeville, SC 29927 843/707-1018 Fax: 843/707-1016 Category: Affiliate Member Parent Company: MJ Walk LLC/ dba Carolina-Walk Orthotics & Prosthetics, Port Royal, SC
Norell Prosthetics-Orthotics 205 South Drive Mountain View, CA 94040 650/968-7464 Fax: 650/960-0348 Category: Patient-Care Member Kathy Rich
Ortho Pro of Reno 487 Casazza Drive Reno, NV 89502 775/324-1443 Fax: 775/324-1663 Category: Affiliate Member Parent Company: OrthoPro of Twin Falls Inc., Twin Falls, ID
Is Your Facility Celebrating a Special Milestone This Year? 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 email@example.com.
Pacific Medical P&O 190 N. Wiget Lane, Ste. 109 Walnut Creek, CA 94598 925/935-9194 Fax: 925/935-9591 Category: Affiliate Member Parent Company: Pacific Medical P&O, Tracy, CA
Pacific Medical P&O 1560 N. 115th Street, Ste. G-10 Seattle, WA 98133 206/368-5851 Fax: 206/368-1121 Category: Affiliate Member Parent Company: Pacific Medical P&O, Tracy, CA
Sumter Prosthetics and Orthotics 259 Broad Street Sumter, SC 29150 803/883-4356 Fax: 803/883-4386 Category: Affiliate Member Parent Company: Carolina Orthotics & Prosthetics Inc., N. Charleston, SC
The Brace Place Inc. 3719 24th Street Lubbock, TX 79410 806/792-0395 Fax: 806/792-0396 Category: Patient-Care Member Nancy Spradling
Western Carolina O&P 170 E. Walker Street East Flat Rock, NC 28726-2235 828/595-9371 Fax: 828/595-9373 Category: Affiliate Member Parent Company: Carolina Orthotics & Prosthetics Inc., N. Charleston, SC a
UPS Savings Program Proteor DynaStar Foot from PEL Offering the innovative combination of a long carbon-fiber keel and a hard heel that are linked together by a single PU joint, this K3 foot offers stability and comfort to moderately active amputees. The lightweight (345 kg) DynaStar Foot utilizes a split keel in the forefoot to provide more natural eversion-inversion movements, while a rear stop absorbs possible activity overload. With an upper blade made of carbon composite, and an aluminum lower strut, the combined action of the PU link and carbon blade allows for smoother and more flexible shock absorption by improving the absorption of foot rotation at heel strike. The Proteor DynaStar Foot is one of the best valued L5981 feet on the market. Available in four modules, it is delivered complete with foot shell, Spectra sock, and malleolar clip and carries a weight limit of 275 lbs. Contact PEL at 800/321-1264 or visit www.pelsupply.com.
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®
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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!
JANUARY 2014 O&P Almanac
Find your region on the map to locate jobs in your area.
- Northeast - Mid-Atlantic - Southeast - North Central - Inter-Mountain - Pacific
Classified rates Classified advertising rates are calculated by counting complete words. (Telephone and fax numbers, email, and Web addresses are counted as single words.) AOPA member companies receive the member rate. Member Nonmember Words Rate Rate 50 or fewer words $140 $280 51-75 words $190 $380 76-120 words $260 $520 121 words or more $2.25 per word $5.00 per word Specials: 1/4 page, color 1/2 page, color
Job board rates Visit the only online job Member Nonmember board in the industry at Rate Rate jobs.AOPAnet.org! $80 $140
Be served a bigger
slice of the pie!
dollar of of the 3.5 billion AOPA Find your slice begin with an O&P business— opportunity today! advertising
American Orthotic Promoting O&P
Jan. 1, 2014
DISCOVER more AOPA advertising opportunities. Call Bob Heiman, Advertising Sales Representative, at 856/673-4000 or email firstname.lastname@example.org
O&P Almanac JANUARY 2014
CPO OR Board-Eligible CPO Traverse City, Michigan We are seeking a motivated CPO or board-eligible CPO for our Traverse City location. Teter O&P is a privately-owned company with 20 locations in Michigan. We offer a competitive salary, good benefits, and paid continuing education. If quality of life is important, you won’t be disappointed with us or a beautiful area to live in. Please send resume to:
Todd Stone, CPO 1225 W. Front Street Traverse City, Mi 49684 Fax: 877/218-1947 Email: email@example.com
$482 $678 $634 $830
Advertisements and payments need to be received approximately one month prior to publication date in order to be printed in the magazine. Ads can be posted and updated at any point on the O&P Job Board online at jobs.AOPAnet.org. No orders or cancellations are taken by phone. Ads may be faxed to 571/431-0899 or emailed to scuster@ AOPAnet.org, along with a VISA or MasterCard number, the name on the card, and the expiration date. Typed advertisements and checks in U.S. currency made out to AOPA can be mailed to P.O. Box 34711, Alexandria, VA 22334-0711. Note: AOPA reserves the right to edit Job listings for space and style considerations. Responses to O&P box numbers are forwarded free of charge. Company logos are placed free of charge.
CPO/BOCPO At Center for Orthotic & Prosthetic Care (COPC) our staff of orthotic and prosthetic professionals is committed to our mission of providing the highest level of patient care possible. COPC is a private partnership that enjoys the privilege and challenge of serving in leading and renowned medical centers in KY, IN, NC, and NY. Due to an opening at a new patient-care facility in Paducah, Kentucky, we are seeking a CPO, or KY licensed BOCPO, with a minimum of 5 years’ clinical experience. Candidates must possess excellent communication, organizational, and interpersonal skills, and the demonstrated ability to provide the highest quality patient care. This position offers a competitive salary, relocation assistance, and excellent benefits including medical, dental, disability, 401K, certification and licensure fees, and continuing education expenses. If you meet these requirements and have an interest, please submit your resume, in confidence, to: via fax at 502/451-5354 or via email to firstname.lastname@example.org.
24/7 Expert Coding Advice 24/7 •
The O&P coding expertise you’ve come to rely on is now available whenever you need it.
Match products to L codes and manufacturers— anywhere you connect to the Internet.
This exclusive service is available only for AOPA members.
Contact Lauren Anderson at 571/431-0843 or landerson@AOPAnet.org.
Log on to LCodeSearch.com and start today. Not an AOPA member? GET CONNECTED
Visit AOPA at www.AOPAnet.org.
Manufacturers: Get your products in front of AOPA members! Contact Joe McTernan at jmcternan@AOPAnet.org or 571/431-0811. JANUARY 2014 O&P Almanac
■ 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 multiplechoice and clinical-simulation exams. Apply now at http://my.bocusa.org. For more information, visit www.bocusa.org or email email@example.com.
www.bocusa.org ■ 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.
■ On-site Training Motion Control Inc. On-site Training Course is focused on the expedited fitting of your first patient. Course Length: 3 days, CEUs: 19.5 hours (estimated). Recommended for prosthetists with a patient ready to be fit immediately. For more information, call 801/326-3434, email info@ UtahArm.com, or visit www.UtahArm.com.
2014 ■ January 3-4 ABC: Prosthetic Clinical Patient Management (CPM) Exam. St. Petersburg College Caruth Health Education Center, St. Petersburg, FL. Contact 703/836-7114, email firstname.lastname@example.org, or visit www.abcop.org/certification.
PROMOTE Events in the O&P Almanac
CALENDAR RATES Telephone and fax numbers, email addresses, and websites are counted as single words. Refer to www.AOPAnet.org for content deadlines. Words
25 or less................... $40..................................$50 26-50......................... $50..................................$60 51+................... $2.25 per word................$5.00 per word Color Ad Special: 1/4 page Ad.............. $482............................... $678 1/2 page Ad.............. $634............................... $830 BONUS! Listings will be placed free of charge on the Attend O&P Events section of www.AOPAnet.org. Send announcement and payment to: O&P Almanac, Calendar, P.O. Box 34711, Alexandria, VA 22334-0711, fax 571/431-0899, or email scuster@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. For information on continuing education credits, contact the sponsor. Questions? Email scuster@AOPAnet.org. 46
O&P Almanac JANUARY 2014
■ January 8 AOPAversity Audio Conference–New Year, New Opportunity: Are You Billing for All That You Can? Register online at http://bit. ly/aopa2014audio. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.
■ January 13-18 ABC: Written and 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. Contact 703/836-7114, email email@example.com, or visit www.abcop.org/certification. ■ January 25-26 The Foot and Ankle—from Athletic to Decrepit. Sanford, NC. Study pathology-based treatments, orthotic fabrication, and shoe prescriptions while supporting a good cause. 16.00 credits. Register at FootCentriconline.com. ■ JANUARY 26-29 U.S. Member Society of ISPO: Pac Rim 2014: Learning Beyond Our Horizons—A Biennial Symposium on Prosthetics, Orthotics, & Rehabilitation. Wiakoloa Beach Marriott Resort and Spa on the Big Island of Hawaii. Learn about progressive treatment options and innovations and hear from recognized physical rehabilitation professionals while enjoying attractions on the Big Island. Contact Dianne Farabi at 614/659-0197 for more information. Submit abstracts at www.usispo.org/pacrim14.
■ February 1 ABC: Practitioner Residency Completion Deadline for March 2014 Exams. Contact 703/836-7114, email firstname.lastname@example.org, or visit www.abcop.org/certification. ■ FEBRUARY 10-11 AOPA: Essential Coding & Billing Seminar. Royal Sonesta. New Orleans. To register, contact Betty Leppin at 571/431-0876 or bleppin@ AOPAnet.org.
■ February 12 AOPAversity Audio Conference–Billing for Diabetic and Orthopedic Shoes, Mastectomy Services, and Surgical Dressings. Register online at http://bit. ly/aopa2014audio. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.
■ FEBRUARY 26-MARCH 1 40th Academy Annual Meeting & Scientific Symposium. Chicago. Hyatt Regency Chicago. For more information, contact Diane Ragusa at 202/380-3663 x208, or email@example.com. ■ MARCH 12 AOPAversity Audio Conference–The ABCs of Audits: What to Expect and How to Respond. Register online at http://bit. ly/aopa2014audio. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.
■ April 3-4 Rehabilitation Institute of Chicago: Advanced Pediatric Gait Analysis. Chicago. Must have taken an Elaine Owen course as prereq. 15.00 ABC credits. Contact Melissa Kolski at 312/238-7731 or visit www.ric.org/education.
■ APRIL 7-8 AOPA: Essential Coding & Billing Seminar. Bally’s Hotel & Casino. Las Vegas. To register, contact Betty Leppin at 571/431-0876 or bleppin@ AOPAnet.org.
■ June 11 AOPAversity Audio Conference–The Self-Audit: A Useful Tool. Register online at http://bit.ly/aopa2014audio. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.
■ April 9 AOPAversity Audio Conference–How To Use Advanced Beneficiary Notices (ABNs) Effectively. Register online at http://bit. ly/aopa2014audio. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.
■ July 9 AOPAversity Audio Conference–The OIG: Who Are They and Why Are They Important? Register online at http://bit.ly/aopa2014audio. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.
■ May 14 AOPAversity Audio Conference–Modifiers: How and When to Use Them. Register online at http://bit. ly/aopa2014audio. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.
■ August 13 AOPAversity Audio Conference–AFO/KAFO Policy: Understanding the Rules. Register online at http:// bit.ly/aopa2014audio. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.
■ SEPTEMBER 4-7 97th AOPA National Assembly. Las Vegas. Mandalay Bay Resort & Casino. For more information, contact AOPA Headquarters at 571/431-0876 or info@ AOPAnet.org.
■ September 10 AOPAversity Audio Conference–Urban Legends in O&P: What To Believe. Register online at http://bit. ly/aopa2014audio. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.
■ October 8 AOPAversity Audio Conference–Medicare Enrollment, Revalidation, and Participation. Register online at http://bit.ly/aopa2014audio. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.
■ November 12 AOPAversity Audio Conference–Gifts: Showing Appreciation Without Violating the Law. Register online at http://bit.ly/ aopa2014audio. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.
■ December 10 AOPAversity Audio Conference–New Codes and Changes for 2015. Register online at http://bit. ly/aopa2014audio. For more information, contact Betty Leppin at 571/431-0876 or email bleppin@AOPAnet.org.
2015 ■ OCTOBER 7-10 98th AOPA National Assembly. San Antonio. Henry B. Gonzales Convention Center. For more information, contact AOPA Headquarters at 571/431-0876 or info@ AOPAnet.org. a
Hersco Ortho Labs
and Review Guide
Orthotic and Prosthetic Study
JANUARY 2014 O&P Almanac
Do Your Homework
Answers to your questions regarding RAC activities, PTAN requirements, and more
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 firstname.lastname@example.org.
How can I find out what items/services the Recovery Audit Contractors (RACs) are reviewing?
The RACs are required to publish the areas of vulnerability or issues they are targeting for their recoupment activities. Each RAC includes an area on its website where you may view what issues or types of claims it is auditing. In addition to visiting the website of the RAC from your area, consider visiting the websites of the RACs in other jurisdictions as well. Here are the websites for each RAC:
• Jurisdiction A: Performant Recovery, www.dcsrac.com
• Jurisdiction B: CGI, http://racb.cgi.com • Jurisdiction C: Connolly Inc., www.connollyhealthcare.com/RAC • Jurisdiction D: HealthDataInsights, https://racinfo.healthdatainsights.com.
O&P Almanac JANUARY 2014
We have multiple offices, but our billing is done from a central location. Does each office require a separate Provider Transaction Access Number (PTAN), or Medicare Supplier Number, and National Provider Identifier (NPI) number?
Yes. The PTAN and NPI numbers are not attached to a specific billing location, but rather are attached to each physical location where Medicare services are rendered. You are not required to bill from each location, but your claim should indicate where the service was rendered. This is why the CMS-1500 form has the separate boxes for billing location and services rendered location. Even if you do all of your billing from one central location and under one main PTAN number, you will want to submit at least one claim a year from each of your satellite offices. If a claim is not sent from a PTAN number for a period of time—four consecutive quarters— Medicare will assume it is non-active and they will de-activate the PTAN number.
If we are a nonparticipating provider and we choose not to accept assignment on a claim, are we still required to obtain all of the documentation and paperwork required by Medicare?
Yes, you still must collect all of the required and proper documentation and paperwork. Being a nonparticipating provider and not accepting assignment on a claim does not release you from the obligations of meeting Medicare policy requirements; it only affects how much money you may collect from the patient and who is responsible for paying you on the claim. a
Back on his feet.
And moving at the speed of life. With the C-Brace. Until now, people with paresis of the quadriceps, post-polio syndrome, and some types of incomplete spinal cord injury had limited choices. Now Ottobock opens a whole new world of mobility with the remarkable Orthotronic Mobility System: C-Brace速. Imagine fluid, natural, efficient movement with support on uneven terrain, on inclines, and going down stairs. In daily life, it means a walk in the park can be just that. Contact your Ottobock sales representative at 800 328 4058.