On October 1, 2002, the ABC participated in the first meeting of the Consensus Committee as mandated by the Negotiated Rule Making section of BIPA 2000. This legislation requires the formation of a committee of interested organizations to recommend qualification criteria for Medicare reimbursement of O&P services. In addition to the ABC, the BOC and another 19 organizations will participate in this process. The following represents the ABC’s opening statement and the principles that will guide our involvement:
“The ABC is a not-for profit, 501C(6) organization, incorporated in 1948. It is the first credentialing organization for the orthotic and prosthetic allied health profession. At present, we certify 3,570 orthotists and prosthetists; register more than 800 orthotic and prosthetic technicians and associates; and we accredit 750 O&P organizations, representing 1,215 patient care sites. Our certified practitioners span all fifty states, Puerto Rico and Washington, D.C. ABC certifees also practice in Canada, Mexico, Western and Eastern Europe and Asia.
We appreciate the opportunity to participate in this consensus process and look forward to a productive outcome. Our goal is to support criteria that emphasizes competent, and safe treatment of orthotic and prosthetic patients. Such criteria should also promote accessibility to quality, cost effective care. We have provided the committee with documentation that more comprehensively describes our programs and standards.For 54 years, the ABC has developed and administered programs to identify those who possess the necessary qualifications to provide O&P services. Today’s standards follow the AMA’s 1991 decision to recognize orthotics and prosthetics as an allied health profession. They include education and training standards adopted by the Commission on the Accreditation of Allied Health Education Programs (CAAHEP) and the National Commission on Orthotic and Prosthetic Education (NCOPE). We also note that our standards are embodied in every state orthotics and prosthetics licensure law, and ABC examinations are exclusively used by those states that have subsequently enacted regulations to administer those laws. In addition, ABC standards are identical to the minimum requirements established by the International Society of Prosthetics and Orthotics for practitioners in Europe, Asia and the developing countries.
The evolution of our standards reflect the increasing sophistication of orthotics and prosthetics as it evolved from the “art” of its origins at the turn of the century to the “science” of present day care. As with medicine and other segments of health care, orthotics and prosthetics has witnessed an explosion in technology and the need for a deeper understanding of the complex medical disorders underlying a patient’s needs. It requires a broad base of knowledge in such diverse subjects as anatomy, physiology, disease pathology, and biomechanics just to name a few. Practitioners must also be educated and trained in a comprehensive body of knowledge associated with orthotics and prosthetics
With respect to qualifications for suppliers/facilities, we believe they should demonstrate compliance with standards that promote organizational excellence and address governance, professional staff qualifications, quality assurance, patient care, and facility safety. Furthermore, federal regulations that require supplier compliance activities to eliminate fraud and abuse and activities to protect the privacy and confidentiality of patient information should also be embraced by such standards.
In summary, the ABC believes that the Medicare program enjoys a unique opportunity to promote the delivery of quality O&P care to a growing population of beneficiaries. Our participation in the committee’s deliberations will be guided by the following principles:
1. Qualified practitioners should meet essential education and training requirements, as represented in the CAAHEP and NCOPE standards.2. Qualified suppliers/facilities should meet specific standards of organizational excellence that support the provision of quality O&P patient care. Such standards should address issues affecting quality patient care, safety and compliance with federal regulations, not merely the physical setting in which such care is rendered.
We hope other members of the committee will agree that education and specific formal training in orthotics and prosthetics are the minimum requirements for individuals to competently provide these services to Medicare beneficiaries. They deserve no less.”