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David McGill Blogger

Orthotics Undefined

Posted by David McGill | March 08, 2014

On February 28, we posted regarding the MACs' publication of guidance for the terms "off-the-shelf orthotics," "custom-fit orthotics," "custom-fabricated orthotics," and "qualified practitioner."

Last Friday, the MACs decided, without explanation, to retract their previous statement. Region C made the announcement first in a terse statement, and we expect the other MACs to formally follow suit today

What does this mean for you?

Let's start with what this does not mean.

This in no way eliminates or changes the new "exploded codes" separating prefabricated orthotics into either off-the-shelf on the one hand, or custom-fit on the other. And the fact remains that qualified practitioners are still the only individuals permitted to deliver custom-fit and custom-fabricated orthoses.

What the retraction does do is eliminate the guidance "clarifying" the definition of the 4 terms listed in the opening paragraph of this post. So, for example, just what qualifications a "qualified provider" must have remains an open question.

With the elimination of the MAC guidance, we're therefore right back where we were as of January 1 - you are responsible for determining whether your products are off-the-shelf, custom-fit, or custom-fabricated, and in the latter 2 instances, whether a "qualified practitioner" fit them. But the exact meaning of those terms remains unclear.

While we've heard rumors that Medicare may issue additional guidance between now and the end of March, we cannot confirm their veracity. The only thing that we can responsibly recommend in the interim is that you carefully consider each of the 4 terms and use your best judgment as to their meaning.

We will keep you posted as new facts become available.

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